Process Safety eHANDBOOK

Protect Plants from

Process
Perils
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 www.ChemicalProcessing.com

TABLE OF CONTENTS
PSM Audits Find Confusion Common  6
Issues with operating/safe limits tables arise all too frequently

Safely Use Mobile Devices  15

Understanding ignition sources and levels of device protection
are crucial to eliminating risk

Understand Pressure Effects on Combustible Dust  19

Vessel protection systems help guard against catastrophic explosions

Up Your Fired Heater Safety with TDLS Technology  26

These analyzers offer quick and accurate live gas readings

Additional Resources  32

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packing materials that can make lined hoses even heavier and less flexible.

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Process Safety eHANDBOOK: Protect Plants from Process Perils 3

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PRODUCT FOCUS
FERST SOFTWARE PROVIDES SAFETY
AND RELIEF CALCULATIONS

The Fauske Emergency Relief System Tool (FERST), powered by

ChemCAD, allows users to obtain a vent size quickly for reactive
and nonreactive upset scenarios. The program includes a license
to the DIPPR database granting direct access to more than 2,500
pure component material properties and 40 different thermo-
dynamic mixing models to support the calculations and provide
additional understanding of potential safety concerns.
It is designed to provide recommendations for new, or evaluations of existing, rupture disks
and safety relief valves, including allowable inlet and outlet frictional losses within a relief line.
Sources of overpressure for consideration include reactive vapor systems, reactive hybrid
systems, reactive systems and constant heating (e.g., fire exposure) nonreactive vapor sys-
tems. Two-phase flow can be considered with churn-turbulent, bubbly and homogeneous flow
regimes incorporated.
The software offers GUI functionality in file handling and results reporting and has customizable
plotting capabilities. It also provides a staged approach to emergency relief system design by includ-
ing options to build upon the design and fine tune the analyses by manipulating a range of variables.

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Process Safety eHANDBOOK: Protect Plants from Process Perils 5

 www.ChemicalProcessing.com

PSM Audits Find

Confusion Common
Issues with operating/safe limits tables arise all too frequently
By James A. Klein and James R. Thompson, ABSG Consulting

P
rocess safety audits [1, 2] serve two
main purposes: (1) feedback on
process safety program implementa-
tion and effectiveness to identify potential
opportunities for improved performance,
and (2) compliance with process safety reg-
ulations such as the 29 CFR 1910:119 Process
Safety Management (PSM) regulation of the
U.S. Occupational Safety and Health Admin-
istration (OSHA) and the 40 CFR 68 Risk
Management Program (RMP) rule of the U.S.
Environmental Protection Agency (EPA).
A facility with a process covered by these
regulations must conduct compliance audits
every three years. Facilities in existence when
OSHA promulgated its regulation in 1992
now have performed seven to nine compli-
ance audits. A review of recent audit findings
for both long-established and newer plants
suggests certain shortcomings continue to
commonly arise. This article looks specifically
at issues related to operating limits, required
under the operating procedure (OP) element,
and safe limits, required under the process
safety information (PSI) element — and pro-
vides guidance on how to avoid such findings
through appropriate development and imple-
mentation of limits tables.
Operating limits and safe limits tables are
important because they define the ranges of
safe operation for a process, both as operat-
ing limits in the OPs and as the ultimate safe
(or design) limits in PSI. Exceeding operating
limits can prompt process upsets, quality
issues and other problems. Deviating outside
safe limits likely will cause significant process
incidents and result in possible equipment
damage, personnel injuries and environmental

Process Safety eHANDBOOK: Protect Plants from Process Perils 6


harm. Failure to properly document these
limits can lead to improper operation as well
as major operability and safety issues. So, a
plant must spell out the consequences of the
deviations from these limits, including the
safety and health effects on personnel. The
OPs must specify correct operator responses
to regain desired control of the process. Many
companies choose to combine these sets of
limits tables as part of the OPs for ease of
reference and use; this, while common, some-
times also becomes a source of confusion if
the information is not clearly presented.
Based on our experience, having a complete,
accurate and thorough set of operating
limits and safe limits tables available to
process operators (particularly board oper-
ators) as well as engineers, maintenance
staff, etc., is invaluable in (1) focusing them
on the important process parameters, (2)
reminding them of the worst-case conse-
quences associated with going beyond these
parameters, and (3) providing a ready ref-
erence for actions to take when parameters
Process Safety Operating
Information Procedures
Upper/Lower Upper/Lower
Safe Limits Operating Limits
Consequences of Consequences of
Deviation, including Deviation
those affecting the
safety and health Steps required to correct
of personnel or avoid deviation
SEPARATE SAFE AND OPERATING
LIMITS TABLES
Figure 1. Creating distinct tables can avoid
confusion about the type of limit.
Process Safety eHANDBOOK: Protect Plants from Process Perils 7
www.ChemicalProcessing.com
are exceeded. Limits tables, therefore, are
important training tools. Exceeding one
flow rate may have minor consequences but
exceeding a different flow rate could lead
to destruction of the plant. Knowing these
differences and how to respond to these
deviations are fundamental to safe design,
operation and maintenance of the plant.
Many companies refer to “safe operating
limits” (SOLs), which also can lead to con-
fusion because the OSHA regulation refers
only to safe limits and operating limits. SOL
implies that safety, rather than other con-
siderations, determined the operating limits.
However, SOLs should not necessarily be
equated to safe limits. Auditors should
understand company intent and practice
relative to the OSHA PSM regulation to
determine if requirements are being met.
REQUIREMENTS/BACKGROUND
The OSHA PSM requirements for operat-
ing limits and safe limits appear in OSHA
29 CFR 1910:119. OSHA provides additional
guidance in its “Petroleum Refinery Process
Safety Management National Emphasis
Program” [3] and “Process Safety Manage-
ment Supplement B, Voluntary Protection
Program” [4]. EPA mandates basically the
same requirements in its RMP rule.
Two basic approaches exist for meeting
these requirements:
1. Implementing the PSI and OP require-
ments separately, with the PSI safe limits
 www.ChemicalProcessing.com

tables providing the basic process vari- Operating Procedures

ables to be addressed in the operating Upper/Lower Safe and Operating Limits
limits tables in the OPs (Figure 1); or
Consequences of Deviation, including those affecting
2. C
 ombining the PSI and OP requirements the safety and health of personnel

into limits tables in the OPs (Figure 2). Steps required to correct or avoid deviation

COMBINED SAFE AND OPERATING LIMITS

Both approaches are valid for meeting the TABLE
Figure 2. A table containing both kinds of limits
regulatory requirements — and both have can reduce the chance of discrepancies arising
pluses as well as minuses if not imple- over time.

mented and maintained appropriately. For

example, combined tables help reduce part of refresher training activities. How-
discrepancies that could develop over ever, improper design and implementation
time in separate tables as process equip- of combined tables can lead to confusion
ment changes occur. Combined tables also around whether limits are safe limits, oper-
undergo periodic scrutiny as part of OP ating limits or something else (e.g., control
reviews to confirm they are current and system alarm points). Table 1 shows an
accurate; therefore, they frequently are example combined limits table.

EXAMPLE OF OPERATING/SAFE LIMITS TABLE

Consequences Safe Consequences Corrective
Parameter Normal of Deviation Corrective Limits of Deviation Action
Instrument (Process Operating (exceed Normal Action Do Not (exceed Safe (exceed
Tag Variable) Limits Limits) (Troubleshooting) Interlocks Exceed Limits) Safe Limits)

TC-1700 XX-201 Max: Max: •R

 educe air flow TC-1700 will Max: High temperature • Shut off air
Temperature 95°C Poor yield and to oxidizer. activate and: 120°C leads to runaway to oxidizer.
increased side reaction.
• Increase water 1. s hut off the air • O pen cooling
Min: reactions; begin to Min: Temperature
flow to to the oxidizer water valve to
85°C approach runaway N/A increases quickly,
circulation cooler. and circulation coolers
reaction. resulting in a
to 100%. Divert
2. o
 pen water release of gas that
additional cooling
Min: valves to may cause a fire/
water if needed.
Loss of reaction circulation explosion hazard
and lower peroxide coolers 100% to personnel. • Refer to procedure
concentration in if reading is XX “Response to
oxidizer; above 105°C. High Temperature
operability/quality in an Oxidizer”
issues. for further steps.

AI-1703A XX-201 Max: Max: Increase tempera- AI-1703A/B will Max: Explosive atmo- • Shut off air to
AI-1703B Offgas 9% Approach ture to the oxidizer activate and shut 20% sphere is present the oxidizer.
Oxygen explosive by off the air to the in the oxidizer,
• O pen nitrogen
Percentage Min: atmosphere oxidizer if reading Min: resulting in a fire/
1. reducing water valve to the
4% in the oxidizer. above 15%. N/A explosion hazard
flow to the cir- oxidizer vapor
to personnel if an
culation cooler, space.
Min: ignition source is
Poor yield 2. increasing present. • Increase oxidizer
and increased steam flow temperature
side reactions. to the before putting
pre-heater, or air back on the
oxidizer.
3. p
 utting steam
on the circula-
tion cooler.

Table 1. Clearly differentiating between normal operating limits and safe limits is essential

Process Safety eHANDBOOK: Protect Plants from Process Perils 8


Figure 3 provides a typical way of
thinking of limits. Most processes will
have a normal operating zone, such as
a temperature range from 100–120°C,
based on safety, quality and other
operability considerations. This range
is used to define the desired upper
and lower operating limits. Deviations
above or below the operating limits
will result in troubleshooting activi-
ties by operators and/or automatic
response by the control system to
return to normal conditions. Usually a
response zone is defined before safe
limits are exceeded, although the avail-
able response time may be very short.
In some cases, a buffer zone may exist
above the safe limits before worst-case
consequences can occur. However, in
many cases, the safe limit defines the
point where undesirable safety conse-
quences are possible without a buffer.
Figure 4 shows these limits and the
activation points for possible process
safeguards for pressure in a reactor
due to a runaway reaction, based on
layers of protection as evaluated in a
process hazard analysis (PHA).
COMMON AUDIT ISSUES
While the limits table requirements, as
shown in Figures 1 and 2, seem relatively
straightforward, large processes may need
to document literally hundreds of limits.
Critical variables may include temperature,
pressure, flow rates, levels and many other
Process Safety eHANDBOOK: Protect Plants from Process Perils 9
www.ChemicalProcessing.com
Process Incidents/Near Misses
Buffer Zone
Upper safe limit
Response Zone
Upper operating limit
Normal Operating Zone
Lower operating limit
Response Zone
Lower safe limit
Buffer Zone
Process Incidents/Near Misses
ZONES OF OPERATION
Figure 3. Most processes have a normal operating
range with various limits addressing excursions.
Maximum Allowable Working Pressure
Upper Safe Limit
Pressure Relief (Pressure Safety Valve)
Pressure
Safety Instrumented System (Inhibitor Addition)
Upper Operating Limit (High/High Alarm)
Control System (High Alarm)
Time
EXAMPLE PRESSURE LIMITS FOR A RUNAWAY
REACTION
Figure 4. This chart is a modified version of one
in “Process Safety: Key Concepts and Practical
Approaches” [5].
variables for each piece of process equip-
ment. Developing this information can be
a challenge, especially for older processes,
due to limited availability of the PSI. With
multiple requirements for developing,
documenting and maintaining limits, it is
not surprising that process safety audits
often identify compliance or improvement

opportunities related to limits tables. In
addition, changing equipment design or
regulatory direction may raise issues not
found in previous audits.
So, let’s now look at five common issues
with operating/safe limits observed in PSM
compliance audits:
1. Separate operating and safe upper/
lower limits are not provided. The OSHA
regulation and good industry practice
clearly require/expect each covered pro-
cess to have two separate sets of limits:
• Operating limits, defining the boundaries
outside of which a system upset or abnor-
mal operating condition could occur; and
• Safe limits, representing the design safe
upper and lower limits of the equipment
or process, above or below which opera-
tion is considered unsafe.
However, some facilities still:
• Establish only one set of documented
“limits” rather than two sets; it often is
not clear whether they are operating or
safe limits.
• Specify operating limits in tables in the
OPs but do not include safe limits in these
OP tables or in separate tables as part of
the PSI. The reverse of this (i.e., estab-
lishing safe limits in tables in the PSI but
not operating limits in tables in the OPs)
occurs less commonly.
• Reference the alarm/interlock settings in
the distributed control system (DCS) and
Process Safety eHANDBOOK: Protect Plants from Process Perils 10
www.ChemicalProcessing.com
the pressure safety valve (PSV) settings as
providing the operating/safe limits.
The first and second instances clearly do
not comply with the regulations because
they do not provide both sets of required
limits. In the third instance, many DCS
alarm settings are not established for safety
reasons but for quality or operability pur-
poses. Therefore, defaulting to the DCS
parameters may indicate the requirements
of operating limits are not well understood.
In some cases, safe limits also may appear
in the tables but be difficult to distinguish
from quality, environmental and other limits.
Guidance: Ensure (1) both operating and
safe limits are provided in the PSI, OPs or
combined tables, and (2) the limits documen-
tation addresses, as applicable, the different
zones of operation shown in Figure 3. Also,
avoid imprecise terminology when possible.
2. All pertinent operating/safe limits are
not addressed. In some cases, inspection of
the limits tables may suggest certain critical
variables are missing (e.g., temperature in
a reactor), leading to additional discussion
with site personnel to understand (1) how
the limits tables were developed and (2)
why, in the case of high temperature in a
reactor, the particular limits have not been
established. Operating/safe limit tables for
all the pertinent process parameters can
be effectively evaluated (as time permits)
by comparing the limits tables data to the

current PHA for the process and other PSI
documentation. This can be done by:
• Reviewing the PHA report worksheets
for parameter deviations leading to
potential hazardous events (e.g., loss of
containment) that are not addressed in
the operating/safe limits. For example,
if high flow or high level in a hazard and
operability (HAZOP) table is shown to
lead to hazardous events in the PHA,
then it would be reasonable that limits for
these variables should appear in the limits
tables. Note: PHAs typically do not pro-
vide the actual limits. Use the PSI to find
this information.
• Checking listed safeguards in the PHA
(e.g., alarms, interlocks and PSVs) or a
separate safeguards table (if available)
to determine if the operating/safe limits
table includes the associated process
parameters. If a high flow alarm or PSV
appears as a safeguard, then it would be
reasonable for the limits table to contain
limits for flow or pressure.
• Scrutinizing PSI documentation (e.g., pro-
cess and instrumentation diagrams and
equipment design files) for specific equip-
ment to see if the limits table correctly
lists design limits.
A review of PHAs and other PSI documen-
tation may show the operating/safe limits
tables lack a significant number of pertinent
process parameters. This situation often
develops because the operations and engi-
neering personnel developing/updating the
Process Safety eHANDBOOK: Protect Plants from Process Perils 11
www.ChemicalProcessing.com
limits tables perform this work independently,
without ever looking at the operating/safe
limits through the “lens” of the PHA reports
or PSI documentation. Audits also provide an
opportunity to review the “reasonableness” of
the limits. For instance, if the limits table lists
a high pressure safe limit of 100 psig while the
PSI or PHA shows the related PSV setpoint as
150 psig, a further discussion to understand
the difference is warranted.
Guidance: (1) Review PHAs and other PSI
documents to ensure the limits table con-
tains appropriate process variables and
values appear correct, (2) clearly address
both upper and lower limits and note as
“not applicable” where no high/low limit
exists, and (3) check relevant process
change documentation to see if limits tables
have been updated as needed.
3. Consequences of deviation are not
clearly documented. The impact of exceed-
ing both operating and safe limits must
be documented. For operating limits, a
simple description such as “process upset”
or something similar often appears — but
this does not adequately describe the pos-
sible consequences. The PSI element also
requires the consequences of deviation
from safe limits include those “affect-
ing the safety and health of employees,”
which often is not addressed as part of the
consequences. Fundamentally, all these
consequences should (1) be consistent,
(2) appear in the PHA worksheets, and

(3) describe potential safety and health
impacts on personnel, as well as effects on
processes and equipment. For example, the
PHA and safe limits table for high pressure
in a reactor might indicate overpressure
leading to loss of containment and potential
toxic exposure to a specific chemical(s) or
fire/explosion hazards.
Audits of consequences of deviation
often find:
• Worst-case consequences are not ade-
quately addressed (no column provided or
left blank).
• Consequences are worded “leading to
a high pressure interlock” or “lifting the
PSV” rather than providing the potential
worst-case consequence of overpres-
suring a vessel and loss of containment.
Note that activation of a PSV also may
result in a hazardous release at the dis-
charge point.
• No mention is made of the safety and
health effects on personnel, such as
potential toxic exposure resulting from the
release of a hazardous chemical.
• Safety consequences are mixed with
operability/quality/environmen-
tal consequences.
Guidance: (1) Review PHAs to ensure proper
documentation of the consequences of
deviation outside the safe limits, including
possible worst cases and potential safety and
health effects on personnel, and (2) clearly
Process Safety eHANDBOOK: Protect Plants from Process Perils 12
www.ChemicalProcessing.com
distinguish between operating/safe limits and
quality, environmental and other limits.
4. Corrective actions are not detailed ade-
quately. OPs must include the steps required
to avoid or correct deviation from operating
limits. However, this information is not always
provided or corrective actions are given for
only some operating limits or with varying
degrees of clarity. Although the regulation
does not specifically require the documenta-
tion of corrective actions for deviations from
safe upper/lower limits, OSHA’s guidance
indicates that “emergency shutdown” should
be a final corrective action. Obviously, the
steps to correct a deviation outside operat-
ing limits will help prevent upset situations or
going beyond safe limits but the necessary
actions likely will differ as a potential devia-
tion approaches or exceeds documented safe
limits. For example, operators typically are
encouraged to safely shut down a process —
even before it reaches an interlock/trip point
or safe limit — when in doubt about contin-
ued safe operation.
Guidance: Review PHAs, OPs, emergency
procedures and other documents as needed
to ensure clear guidance is provided on cor-
rective actions for deviations outside both
operating and safe limits.
5. Process safeguard setpoints are not
included. It is a best practice to detail at what
point various process safeguards will activate

because this helps operators handle process
deviations. What alarms and interlocks are
provided and when will they activate? What
are the setpoints for pressure relief? This
information may be included in the DCS, in
the OPs, in training materials or PSI docu-
ments. Consider adding this information to
the limits tables so an operator immediately
can put them in context with the defined
limits listed in the table. For example, Figure 4
shows a chart that details several safeguards
for high pressure in a reactor to activate as
the upper safe limit is approached. Knowl-
edge of these setpoints as operators respond
to process deviations is important, both so
the operators can anticipate safeguard action
and can respond appropriately if the safe-
guard fails to activate as expected.
Guidance: Consider including process
safeguard setpoints, as appropriate, in the
limits tables.
AVOID COMMON ISSUES
Well-documented operating and safe limits
are an important foundation for safely and
reliably operating processes containing highly
hazardous chemicals. So, process safety reg-
ulations and industry best practices require
clear documentation in OPs and PSI of limits,
consequences of deviation, and corrective
actions. Unfortunately, process safety audits
continue to find poor understanding and inef-
fective implementation of these requirements.
Process Safety eHANDBOOK: Protect Plants from Process Perils 13
www.ChemicalProcessing.com
Hopefully, the information provided here
will help you better evaluate and improve
your operating/safe limits documentation
before you receive a regulatory citation or
compliance audit finding.
JIM KLEIN, CCPSC, CPSA, is a Minneapo-
lis, Minn.-based process safety consultant
with ABSG Consulting Inc. JIM THOMPSON,
CPSA, is a Louisville, Ky.-based process
safety consultant with ABSG Consulting.
Email them at jklein@absconsulting.com
and jthompson@absconsulting.com.
REFERENCES
1. “Guidelines for Auditing Process Safety
Management Systems,” 2nd ed., Center
for Chemical Process Safety/John Wiley &
Sons, Hoboken, N.J. (2011).
2. “ Guidelines for Risk Based Process Safety,”
Center for Chemical Process Safety/John
Wiley & Sons, Hoboken, N.J. (2007).
3. “Petroleum Refinery Process Safety Manage-
ment National Emphasis Program,” OSHA
CPL 03-00-004, U.S. Occupational Safety
and Health Admin., Washington, D.C. (2007).
4. “Process Safety Management Supplement
B, Voluntary Protection Program,” U.S.
Occupational Safety and Health Admin.,
Washington, D.C. (2011).
5. Klein, J.A., and Vaughen, B.K., “Process
Safety: Key Concepts and Practical
Approaches,” CRC Press, Boca Raton, Fla.
(2017).
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Safely Use Mobile Devices

Understanding ignition sources and levels of device protection
are crucial to eliminating risk
By Justin Olivier, Pepperl+Fuchs, Inc.

M
obile devices can solve many
challenges in hazardous industrial
environments — from monitoring
lone workers to enabling predictive mainte-
nance to streamlining field support (Figure
1). But a device that lacks the proper pro-
tection could seriously compromise the
safety of your plant and personnel. Even
something as simple as a hot surface on
an unprotected device can have disas-
trous consequences.

IGNITION SOURCES
Ignition sources are possible even when
unprotected mobile devices are turned
off, including:
• A battery short circuit in an unpro-
HAZARDOUS ENVIRONMENTS
tected device
Figure 1. Mobile devices solve a variety of
• A loose battery in an unprotected device challenges in hazardous areas.

Process Safety eHANDBOOK: Protect Plants from Process Perils 15


• Electrostatic discharge — for instance,
from pulling an unprotected device out of
a holster
Other typical ignition sources include:
• Hot surfaces and open flames
• Electrical arcs and sparks
• Lightning
• Mechanical friction or impact sparks
• Electromagnetic and optical radiation —
i.e., from radios or barcode scanners in an
unprotected device
Intrinsically safe mobile devices ensure
that these potential ignition sources
are removed or prevented (Figure 2).
But to eliminate the risk of explosion,
it is not enough to select just any
protected device.
SAFE MOBILE DEVICES
Figure 2. Intrinsically safe mobile devices ensure potential ignition sources are removed or prevented.
Process Safety eHANDBOOK: Protect Plants from Process Perils 16
www.ChemicalProcessing.com
ZONE/DIV. 1 AND ZONE/DIV.
2 TESTING
Zone/Div. 2 devices are tested only for
the above-listed ignition sources under
normal conditions — not if the device devel-
ops a fault. Zone/Div. 1 devices, on the
other hand, are tested in both normal and
fault conditions.
Further, the batteries in Zone/Div. 2 devices
are not tested for temperature increase under
short-circuit conditions. Only Zone/Div. 1
devices ensure that temperatures remain low
enough to prevent an ignition. In short, Zone/
Div. 1 devices are subjected to more stringent
tests under both normal and fault conditions.
Answer the questions in Table 1 to help
determine whether the smartphones,
 www.ChemicalProcessing.com

QUESTION RESPONSE RISK LEVEL

Are you using Zone/Div. 2 devices in Zone/Div.

Yes High
1 areas?

Are you carrying switched-off Zone/Div. 2 devices

Yes High
through Zone/Div. 1 areas?

Does your Zone/Div. 2 device protect against, and

No High
has it been tested for, all typical ignition sources?

Will your Zone/Div. 2 device be used for multiple

applications in the future, in both Zone/Div. 1 and No High
Zone/Div. 2 areas?

If your Zone/Div. 2 device develops a fault, is it

protected from causing a fire or explosion? (Look for No High
markings such as Ex ic, UL 913, FM2610, or CSA 157.)

Are Zone/Div. 2 and Zone/Div. 1 areas clearly

marked in your plant? Do mobile workers know No High
when they are in a Zone/Div. 1 area?

Does your insurance liability cover incidents

caused by Zone/Div. 2 devices found in Zone/ No High
Div. 1 areas?

ELIMINATE RISK
Table 1. Asking the following questions can help determine whether the mobile devices in your plant
are putting personnel, assets and the environment at risk. Note: This information is intended for
educational purposes only.

tablets, scanners and other mobile devices
in your plant are putting personnel, assets
and the environment at risk.
ELIMINATE RISK
Using the wrong mobile device creates an
enormous amount of risk. To eliminate risk,
follow these basic steps:
• Select manufacturers with a proven track
record of delivering mobile devices for
use in hazardous areas.
• Do not compromise on safety. Always
consult safety and certification
specialists.
JUSTIN OLIVIER is product manager, Mobility,

• Use the correctly certified and marked at Pepperl+Fuchs, Inc. He can be reached at

devices in hazardous areas. jolivier@us.pepperl-fuchs.com

Process Safety eHANDBOOK: Protect Plants from Process Perils 17

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Understand Pressure Effects
on Combustible Dust
Vessel protection systems help guard against catastrophic explosions
By Jeramy Slaunwhite, REMBE Inc.
W
hen handling bulk combus-
tible particulate, the risk of
fire and explosion is a reality
and must be managed to prevent injury,
property damage and production loss.
Industrial fires are more frequent than
explosions, with the primary damage
stemming from the effects of heat and
smoke that then lead to property damage
and limited personnel injuries.
One major difference with explosions is
pressure effects. Combustion, by defini-
tion, generates gases as a byproduct of
the reaction. Unlike the visible flame and
smoke from conventional burning, com-
bustible dust explosions involve rapid
combustion, which produces gases at an
Process Safety eHANDBOOK: Protect Plants from Process Perils 19
www.ChemicalProcessing.com
accelerated rate that is not necessarily
visible but can become evident.
Pressure is transmitted by compressed gases
that exert forces on impingement surfaces
in their path. Pressure effects can be real-
ized in many ways, including open pressure
waves, contained pressure, transferred pres-
sure and released pressure. Open pressure
effects of even a small dust deflagration can
be a motive force, disturbing and elevat-
ing settled dust layers to fuel a secondary
explosion. Expanding combustion gases
pressing on an enclosure’s interior surfaces
can challenge the containment’s integrity,
resulting in catastrophic rupture and rapid
gas and fire release. Pressure can transfer
from one enclosure to another through open

connections, with potentially damaging
effects under various scenarios.
Combustible dust explosion safety con-
siders the occurrence and development of
dust explosions and applies solutions to
manage the hazards. The optimal approach
to explosion safety is preventive measures
to limit fuel or ignition sources; however,
this often is not a standalone, reliable
approach, and provisions must be in place
to protect against dust explosions after
ignition has occurred.
Explosion pressure effects in vessels are
managed by high-strength design and
construction to withstand the pressure
forces, rapid interruption of the combus-
tion process to halt the pressure-inducing
gas production or controlled pressure-relief
venting to exhaust the gases before reach-
ing damaging pressures. The design and
application of explosion safety systems for
process vessels must consider expected
combustion gas pressure, the equipment’s
pressure resistance strength and induced
pressures from the protection system and
the process.
All explosion protection strategies must
take into consideration the fuel of combus-
tion. Combustible dusts can be tested in
accordance with applicable standards to
determine the maximum deflagration pro-
duced pressure in a closed volume and the
rate of pressure rise.
Process Safety eHANDBOOK: Protect Plants from Process Perils 20
www.ChemicalProcessing.com
Higher rates of pressure rise and maximum
pressures will require more responsive
protection systems to manage the rapidly
produced gases and pressure. For dusts,
these material characteristics can vary with
moisture content, particle size distribu-
tion and concentration. This highlights the
importance of testing representative sam-
ples of the actual handled materials.
EXPLOSION PROTECTION BY
PRESSURE CONTAINMENT
Explosion protection by pressure con-
tainment uses high-strength, pressure
shock-resistant vessels designed in accor-
dance with applicable pressure vessel codes
and regulations.
The containment vessel design typically must
be pressure-certified with significant safety
factors as the consequences of failure can be
extreme. Pressure shock-resistant design and
construction is heavy and expensive, increas-
ing exponentially with increases in vessel
size. Connected equipment and explosion
isolation systems also must be considered for
the design and ratings when used as part of a
pressure containment system.
EXPLOSION PROTECTION BY
CHEMICAL SUPPRESSION
Chemical explosion suppression systems
operate by rapidly injecting an extinguish-
ing powder (typically sodium bicarbonate)
into the vessel upon combustion detection.
Deflagration detection often is identified by
 www.ChemicalProcessing.com

a rate of pressure rise associated with rapid
combustion of a dust cloud. To achieve
successful combustion suppression, the
powder must be injected and disbursed in
milliseconds to extinguish the developing
deflagration. This is accomplished by the
powder’s storage and release, in cylinders
and under pressure, where compressed
nitrogen can exceed 800 psi.
While the volume of compressed gas typi-
cally is only around 20 liters per cylinder, the
injected expanding gas imposes pressure
effects on the protected enclosure in addi-
tion to pressure rise from combustion gases
produced up to the point of extinguishment.
The pressure effects of suppressant injection
can be particularly troublesome for small and
large protected volumes. A small protected
vessel has less physical volume to accom-
modate the expanding injection gas and can
experience an elevated residual pressure.
for large low-strength vessels, can approach
or exceed the enclosure’s material strength.
EXPLOSION PROTECTION BY
DEFLAGRATION VENTING
Explosion venting is a passive protection
strategy in which relief vents open at a
defined pressure to relieve the expand-
ing gases and fireball of a dust explosion
inside an enclosure to a safe area. Effective
explosion venting will open at a designed
burst pressure (Pstat) to vent the confined
dust explosion safely so that the maximum
internal pressure (Pred) is maintained safely
below the enclosure strength (Pes).
The Pstat must be less than the Pred to allow
for fast relief and some additional pressure
rise as combustion continues (Figure 1).
Explosion vents typically are single-use rup-
ture panels or hinged reclosing doors with

On the other end of the

spectrum, large ves-
sels often require many
suppressant cylinders
to achieve a reliable
extinguishment cover-
age. The simultaneous
discharge of multiple
cylinders under hun-
dreds of psi of pressure
can produce a surge
EXPLOSION VENTING PRESSURES
pressure in the pro-
Figure 1. Pstat must be sufficiently high to avoid premature opening due
tected volume, which, to process influences.

Process Safety eHANDBOOK: Protect Plants from Process Perils 21


CORRODED EXPLOSION
DOOR LATCH
Figure 2. Hinged explosion
doors are subject to corrosion
and deterioration.
a mechanical closure. Explo-
sion vents are designed and
manufactured to an accepted
standard such as NFPA 68 or
EN 14491. While explosion vents
are not required by NFPA to be third par-
ty-certified, the Pstat of explosion vents must
be reported as a nominal value with a plus
and minus tolerance documented by the
vent manufacturer.
Rupture panel-style explosion vents typi-
cally have a more accurate Pstat and reliable
tolerance than hinged explosion doors,
which can be susceptible to corrosion and
deterioration of mechanical hinges and
latches (Figure 2).
A small delay in vent opening because of
a higher-than-expected Pstat can result in a
detrimental increase of the realized internal
pressure of a vented explosion.
In addition to fuel characteristics, several
strength and pressure factors must be
considered carefully when performing the cal-
culations to determine the required venting
relief area. If the protected vessel is expected
to operate more than 0.2 bar below or above
atmospheric pressure, different calculation
formulae must be used to determine the vent
Process Safety eHANDBOOK: Protect Plants from Process Perils 22
www.ChemicalProcessing.com
area according to NFPA
Standard 68.
Elevated pressure applica-
tions must factor in a higher
vent opening pressure
to avoid premature vent
deployment. Similarly, subat-
mospheric process pressures
must be considered when
selecting and applying explosion vents to
resist the vacuum conditions that could
implode misapplied vent panels (Figure 3).
VESSEL STRENGTH
The primary intent of all explosion protec-
tion systems is to prevent a process vessel’s
catastrophic failure. The reliability of meet-
ing this objective depends highly on the
confidence of defining the enclosure failure
strength. The protection system design is
based on this value with safety factors to
TRIPLE-LAYER EXPLOSION VENT WITH
VACUUM-RESISTANT SUPPORT LAYER
Figure 3. Vacuum conditions can implode vent
panels and must be kept in mind.

ensure the event pressure remains
below the enclosure strength.
For explosion pressure contain-
ment, vessels may be subject to
the requirements of local pres-
sure vessel codes such as ASME
Boiler and Pressure Vessel Code
or EN 14460 Explosion Resistant
Equipment. The reliability of these
design ratings is critical as the
basis of safety and the consider-
ation for extreme consequences
of failure. For pressure-reduced
protection techniques, NFPA 68 Section
6.3.1 provides requirements for the maxi-
mum tolerable pressure. Where enclosure
deformation is not tolerated, the maximum
Pred must be two-thirds of the enclosure
yield strength considering the material of
construction.
This is typical where the enclosure is
intended to be reused following a protected
explosion event. In cases in which plastic
deformation can be tolerated (but rupture
is to be prevented), the maximum Pred must
be two-thirds of the enclosure’s ultimate
strength (Figure 4).
This provides a safety factor between
the calculated maximum pressure and
the enclosure pressure resistance, which
accounts for rapid dynamic stresses from
explosion pressures as compared to static
stresses used for design.
Process Safety eHANDBOOK: Protect Plants from Process Perils 23
www.ChemicalProcessing.com
STRESS-STRAIN CURVE
Figure 4. This chart shows 2/3 yield and 2/3 ultimate stress
added. (https://commons.wikimedia.org/wiki/File:Stress_
Strain_Ductile_Material.png [accessed 2022-03-17])
The enclosure strength or pressure resis-
tance of a vessel can be defined by the
designer or manufacturer or by third-party
engineering analysis. When manufacturers
are defining it, they are attesting to the
equipment’s design and construction typi-
cally by engineering stress analysis design
or physical pressure testing.
When manufacturer strength data is not
available for an enclosure, it must be deter-
mined. In some instances, a conservative
assessment can be used to determine the
maximum tolerable Pred. FM Global loss pre-
vention data sheet 7-76 “Prevention and
Mitigation of Combustible Dust Explosions
and Fire” provides generic assumed Pred
values for typical rectangular and cylindrical
equipment. Caution is recommended when
using assumed or generic values, especially
for existing installations, which can be
subject to influential factors.

EQUIPMENT DAMAGE
Figure 5. This baghouse dust collector shows stress fatigue cracking (left) and hopper hammer
dimpling (right).
These factors on enclosure strength include
the geometry, materials, fabrication meth-
ods and external influences affecting the
condition such as corrosion, modifications,
deterioration and damage. For example, it
may not be prudent to assume the man-
ufacturer or generic strength values for a
vessel in service for 20 years while exposed
to climate conditions or where physi-
cal damage is apparent due to fatigue or
hammering a hopper to aid material flow
(Figure 5).
When considering the risks associated with
estimated or assumed enclosure strengths
in combustible dust explosions, keep in
mind not only the equipment’s condition
but also the consequences of failure on
Process Safety eHANDBOOK: Protect Plants from Process Perils 24
www.ChemicalProcessing.com
people, property and processes. It may be
possible to offset some uncertainty with
engineering judgement in the evaluation of
points of conservatism inherent in a protec-
tion system’s design and the application of
safety factors on design variables.
When evaluating and applying explosion
protection systems, the most significant
consideration should not be how to mini-
mize costs. It can be more advantageous
to understand all the relevant design influ-
ences to optimize the selection, applicability
and reliability of explosion safety systems.
JERAMY SLAUNWHITE, P. ENG., is an explosion safety
consultant at REMBE Inc. Contact him at jeramy.slaun-
white@rembe.us.
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Up Your Fired Heater Safety
with TDLS Technology
These analyzers offer quick and accurate live gas readings
By Kevin Finnan, Yokogawa Corp. of America
I
mproved instrumentation, analytical
technology and proven holistic control
methodologies have enabled fired heater
operators to improve safety while optimiz-
ing efficiency, throughput, emissions and
asset lifespan. Although safety always is pri-
ority number one for fired assets, justifying
expenditures purely for safety purposes can
be difficult. Because other improvements
are tangible, return-on-investment (ROI)
analyses usually dictate investments in
these critical plant components.
Typically, safe heater operation is the
responsibility of a burner management
system (BMS). A BMS uses a controller
that safely allows start-up, normal opera-
tions and shut-down of a boiler, furnace,
heater or other fired asset. During start-up,
the BMS abides by a specific sequence of
Process Safety eHANDBOOK: Protect Plants from Process Perils 26
www.ChemicalProcessing.com
operations that includes purging the com-
bustion chamber of fuel and then bringing
the fired asset to a safe and stable low-
fire condition. To ensure safety, the BMS
employs several interlocks and permissives.
After start-up, the BMS monitors all fired
heater operations and can take immediate
action if it detects an anomaly. For example,
it monitors the burner flame, stopping the
fuel flow in case of a “flame-out.” Similar to
the start-up sequence, the BMS uses a shut-
down sequence with the requisite interlocks
and permissives to ensure safety.
TDLS MEASUREMENT
TECHNOLOGY ENHANCES SAFETY
While a BMS is only as good as its input
sources, a relatively new generation
of analyzers provides further safety
 www.ChemicalProcessing.com

improvement opportunities. Industry

groups have recognized the traditional
approach to O2 content measurement in
gas-fired heaters using zirconium oxide
probes presents a safety hazard because
the probes operate above the methane
(CH4) ignition temperature. Cases have
been documented in which a zirconium
oxide probe ignited natural gas that had
leaked into an idle fired asset. Fired heaters are key components throughout
the process industries.

Analytical techniques include tunable diode

laser spectroscopy (TDLS), which mea-
sures the amount of laser light absorbed
as a beam travels through a gas. A TDLS
analyzer can be installed in a fired asset’s
radiant zone and provide accurate, repeat-
able and uncorrupted live O2 measurements
safely without contacting the process
Safety Inherent
gases (Figure 1). With To The TDLS
no moving parts, Technology
analyzer often will be placed in the cross-
the TDLS analyzer offers a high mean time
n In-Situ
between failure (MTBF) and, thus, a low,
n N2 or Instrument Air Cooling & Glass Cleaning
long-term cost of ownership. Other than the
initial configuration, no regular calibration
is needed.
For fired assets with complex burner
arrangements such as ethylene crackers,
pyrolysis furnaces and reformers, a TDLS
over section between the radiant and
n Interference Free
convection sections.
n Safely non-contacting

Sensor Laser
Control Unit O2 Unit

O2
O2

O2

O2 O2
Mounting
Flange

Gas Flow

© Yokogawa Electric Corporation

TDLS ANALYZER
Figure 1. A TDLS analyzer installed in the fired asset’s radiant zone provides accurate and repeatable
live O2 measurements.

Process Safety eHANDBOOK: Protect Plants from Process Perils 27


TDLS ENABLES A METHANE
BMS PERMISSIVE
In addition to O2, TDLS technology can
provide CO and CH4 measurements. The
methane detection capability allows for
additional safety as the CH4 measurement
can be used as a BMS start-up permissive,
preventing ignition when a dangerous, fuel-
rich condition exists within the fired heater.
Without this detection, heaters are subject
to “huffing” (minor explosions that may not
cause damage) or even more serious and
potentially fatal explosion events.
OPTIMIZING COMBUSTION
CONTROL O2 TRIM
The zirconium oxide probe technology typi-
cally employed for O2 measurements cannot
be located in high-temperature radiant
sections. Usually, they are placed after the
convection section or in the stack, adding
long measurement delays, often more
than 30 seconds. Even worse, this loca-
tion subjects the measurements to tramp
air, arbitrarily skewing the readings based
on various events such as wind, humidity,
ambient temperature and fired asset load.
Not only does the zirconium oxide tech-
nology present a potential ignition safety
risk, but it also contributes to excessive
fuel consumption, excessive emissions and
decreased production.
Conversely, in addition to improving safety,
a TDLS analyzer enables tighter, more
responsive O2 trim control, decreasing
Process Safety eHANDBOOK: Protect Plants from Process Perils 28
www.ChemicalProcessing.com
emissions while improving efficiency and
throughput. In the radiant zone, the TDLS
analyzer can update the BMS or combustion
controls with a live O2 reading on a sub-
two-second cycle.
Using a slow, inaccurate traditional
approach of measuring combustion gases
forces plants to be unnecessarily conserva-
tive with O2 levels. Given complete mixing,
a precise or stoichiometric amount of air
is required to react with a given quantity
of fuel to produce complete combustion.
Because conditions never are ideal in real-
world applications, additional or “excess”
air must be supplied to burn the fuel com-
pletely. Safe combustion at 1% O2 or lower
on gas heaters and furnaces is possible, but
few plants operate their fired asset any-
where close to this level. But if they could
do it safely, why not?
Too little excess air results in a “fuel-rich”
situation, producing a flue gas containing
unburned combustibles such as carbon
monoxide, soot or smoke. This situation
results in a loss of efficiency because not
all the potential energy from the fuel is
captured in the combustion process. Fired
assets that run fuel-rich are wasting fuel,
which increases emissions. In addition, this
is not a safe situation as the unburned fuel
possibly could come into contact with an
ignition source further down the process,
resulting in convection section afterburning
or an uncontrolled explosion.

Efficiency is lost in air-rich combustion because
excessive air flow results in heat loss.
Too much excess air results in an “air rich”
situation, resulting in complete combustion
and safety, but also producing undesirable
effects. Efficiency is lost in air-rich combus-
tion because excessive air flow results in
heat loss. More fuel is required to generate
the same amount of heat flux into the tubes,
so fuel is wasted. Because air consists of
more than 78% nitrogen, increasing the air
used for combustion increases nitrogen
concentration significantly. When exposed
to high combustion temperatures, it can
form “thermal NOx” such as NO or NO2.
The ideal situation is to provide just enough
excess air to produce complete combustion
while providing a minimal safety margin
that accommodates uncontrollable tran-
sients and incorporating an extra level
of security that ensures all combustibles
are consumed.
Meeting these two constraints produces the
highest efficiency, highest production and
lowest emissions while ensuring maximum
safety. The amount of excess air in the flue
gas is determined by measuring the O2 con-
centration. The ideal excess O2 level — the
lowest possible that allows complete com-
bustion — depends on several factors: the
fuel type, the burner type, humidity changes
in the air, moisture content changes in the
Process Safety eHANDBOOK: Protect Plants from Process Perils 29
www.ChemicalProcessing.com
fuel, varying heat demand loads, fouling
of the burner system and mechanical wear
of the combustion equipment. Because
many of these factors are changing contin-
uously, the ideal amount of excess oxygen
constantly varies. What is the ideal excess
air setpoint?
CO TRIM CONTROL FOR
IDEAL EXCESS O2
CO is the most sensitive indicator of incom-
plete combustion. As the amount of excess
O2 is reduced, the emergence of CO will occur
before other combustibles — unburned fuels
— appear. When the concentration of CO
reaches the specified upper limit, the excess
O2 concentration is at its lowest accept-
able level. A minimal oxygen safety factor is
added, becoming the new excess O2 setpoint.
Periodically, the CO breakthrough point can
be tested, thus reestablishing the safe excess
O2 setpoint.
CO trim control of excess O2 concentra-
tion assures minimal energy loss, maximum
efficiency and reduced NOx emissions
independent of heater load, fuel type, LHV,
humidity, moisture content in the fuel and
other variables that make excess O2 control
difficult. The key to obtaining these benefits
is an accurate and reliable measurement of
CO in low ppm levels (Figure 2).

SAFE OXYGEN LEVEL AND CO OVERRIDE
Figure 2. This chart shows an oil-burning heater safely operating at 1.6% O2, less than half the oxygen
level traditionally used by operators of this unit.
CO VISIBILITY IMPROVES SAFETY
CO detection also improves safety by pre-
venting afterburning, which could result in
an explosion. As convection section tube
walls are thinner than the radiant section
tubes, they are not designed for radiant
heating associated with afterburning.
Furthermore, elevated CO is a warning for
accumulated combustibles. Recently, an
ammonia-based fertilizer plant suffered a
severe auxiliary boiler explosion. The root
cause was a faulty exhaust fan, which led to
an accumulation of combustion gases. Not
realizing the severity of the fuel-rich condi-
tion, an operator opened a port to obtain a
better view inside the unit.
The sudden inrush of air caused the explo-
sion. Despite severe burns, the operator
fortunately survived. The boiler and its asso-
ciated steam methane reformer were idled
Process Safety eHANDBOOK: Protect Plants from Process Perils 30
www.ChemicalProcessing.com
for approximately five months while the
auxiliary boiler was replaced, resulting in
tens of millions of dollars of lost production.
HOLISTIC CONTROL BEYOND THE
BMS — OTHER SAFETY BENEFITS
By deploying a holistic methodology that
consists of contemporary measurement
and control technologies in conjunction
with updated operation and maintenance
procedures, fired heater users can realize
significant improvements in energy effi-
ciency, production, asset lifespan — and
safety. The solution is automation plat-
form-independent. Substantially fewer
trips and increased asset life result from
a stabilized coil outlet temperature and
O2 content in the flue gas. For fired assets
such as steam methane reformers which
use catalyst in the tubes, avoiding trips can
be critical to extending the life of the cat-
alyst and delaying an extremely expensive

catalyst change turnaround. Trips always
are inherently dangerous, as well.
A real-time heating value estimate enables
continuous air-to-fuel ratio bias to stabilize
combustion and heat transfer into the tubes.
That calms fired asset operation significantly
while minimizing the thermal stresses on the
tubes, even under conditions such as wide
swings in demand or fuel heating value. This
feedforward LHV information makes the fired
asset easier and, thus, safer to operate.
Well-balanced burners reduce maintenance
costs and allow longer run times between
turnarounds. Balancing the burners and
stabilizing the coil outlet temperature
equalizes the load and reduces the aging
of all radiant section components. Slowing
asset aging improves plant safety.
For ethane crackers, reduced coking results
in fuel savings, more prolonged and cleaner
production runs and maintenance cost
reductions. Stabilized combustion reduces
tube deposits, which accelerate at high
temperatures. By smoothing out tempera-
ture peaks, fired asset operators reduce the
necessary decoking and maintenance time
required. Less decoking and less mainte-
nance equate to improved safety.
CONCLUSION
Contemporary measurement and control
technologies allow fired heater oper-
ators to enhance safety and improve
Process Safety eHANDBOOK: Protect Plants from Process Perils 31
www.ChemicalProcessing.com
performance in a tangible manner that pro-
vides a justifiable ROI.
Operators can realize an immediate safety
improvement by replacing zirconium oxide
probes with TDLS analyzers to measure the
compositions of exhaust gases. The TDLS
technology also enables fast, closed-loop
control of the O2 content, which results in
improvements in fuel efficiency, production,
emissions and asset life.
While a post-combustion CO measure-
ment provides for tighter O2 control, it also
improves safety as a rapid measurement to
determine the presence of unburned fuel
and prevent afterburning.
A TDLS analyzer can also provide the CH4
content to a BMS for use as a “purge com-
plete” permissive.
When used in conjunction with TDLS tech-
nology, a platform-independent, holistic
control technology can improve fired
heater safety and performance by provid-
ing considerable functionality beyond the
existing BMS capabilities. CO trim control of
excess O2, balanced burners, improved heat
transfer, stable coil outlet temperatures
and substantially fewer trips contribute to
these benefits.
KEVIN FINNAN is advisor, Market Intelligence and Strat-
egy at Yokogawa Corp. of America. Reach him at Kevin.
Finnan@yokogawa.com.
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