Thermal Oxidiser Hazards
Thermal Oxidiser Hazards
Thermal Oxidiser Hazards
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INTRODUCTION
Ever increasing global public pressures have prompted many countries to introduce pollution
control legislation to protect the environment. In the UK this has led to the introduction of the
Environmental Pollution Act (EPA) 1990 (Ref 34).
In order to comply with EPA 90, many process and manufacturing industries are having to
install thermal oxidisers (Incinerators or Afterburners) for the abatement of Volatile
Organic Compounds (VOCs) and gases in their process waste streams before discharge to
atmosphere. There are, of course, several other techniques besides thermal oxidation such as
Substitution, Condensation, Adsorption, Liquid Scrubbing, Biological treatment and others.
These are outside the scope of this paper. See reference 46 for advice on other treatment
technologies.
Thermal Oxidisers by their very design operate on generating a flame or intense heat in their
combustion chambers for the destruction of process waste or emissions containing VOCs. If
process conditions upstream, where these emissions are generated, are not properly managed
or controlled thermal oxidisers can pose a significant fire and explosion hazard.
Over the years, both in the UK and abroad, there have been a number of serious fire and
explosion incidents involving thermal oxidisers because companies using them have failed to
either properly manage or control their processes. A number of these incidents have resulted
in fatalities and a significant loss to business. Some of incidents that have been investigated
by the HSE are discussed later in this paper. In the USA, incidents have been reported which
resulted in fatalities (Ref. 36). Other incident descriptions can be found in Refs 39, 40, 41, 42.
The aim of this paper is to ensure that those who operate thermal oxidiser plants and
associated equipment manage and operate them safely and effectively to ensure that
conditions leading to fire and explosion are prevented or at least minimised. This paper does
not include other abatement systems associated with the destruction of domestic, communal,
agricultural, and hospital waste, either as solids or volatile residue sludge.
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In order to ensure uniformity in design, installation and operation of thermal oxidiser plant
across Europe, a recent European standard has been published - EN 12753:1999 (Ref.28)
entitled Thermal cleaning systems for exhaust gas from surface treatment equipment Safety
requirements.
DESIGN & SELECTION
Until the publication of EN 12753 there was no specific standard is available concerning
thermal oxidiser design and associated safety. Reputable manufacturers of thermal oxidisers
may, however, include recommendations contained in Refs. 9, 12, 13 and 14 into their design
philosophy. The unit selected should be appropriate for the full range of foreseeable flows
and compositions. Where more than one plant or process vent discharges into the vent header
system extreme caution should be taken to ensure that the full range of potential operating
conditions have been identified. The amount of time required for this exercise when
retrofitting a thermal oxidiser to an existing plant should not be underestimated. Design of
oxidisers and vent collection systems should be undertaken by suitably qualified persons.
Typical types of thermal oxidisers being used in the chemical and related industries are:
- Simple Thermal Oxidisers. These may be vertical (see figure 1) or horizontal units.
Details of burners and fitments vary widely between manufacturers.
- Oxidisers for hazardous chemical waste streams. These are designed for a more complex
mix of VOCs which require special treatment in order to ensure complete destruction.
Typical features include staged air injection and chemical resistant refractories. (Figure 2)
- Regenerative thermal oxidisers consist of a number of beds filled with ceramic packing
which are used in sequence with the bed that just come off line being used to pre-heat the
incoming gases. Heat recovery of up to 90% is possible with this type of unit. Figure 4.
- Recuperative Catalytic Oxidisers operate at lower temperature and destroy VOCs by a
catalytic reaction. Catalyst is carried on a ceramic matrix. It should be noted that the
catalyst may be poisoned by certain chemicals hence application is limited. (Figure 5).
Incoming gases are pre-heated in a separate exchanger and good heat recovery is possible.
- Regenerative Catalytic Oxidisers are similar to regenerative thermal oxidisers but using a
catalyst. This type is particularly suitable for low VOC concentrations.
- Flameless Thermal Oxidisers may be used for streams containing halogenated or
sulphonated materials which could poison catalysts. These may operate without support
fuels at VOC concentrations ~50% - 60% of the LEL. Figure 3.
- Thermal Oxidiser with Integrated Rotor Concentration System may be used in situations
where the VOC concentration is extremely low (<500ppm). The rotor section contains a
Zeolite which acts as a molecular sieve to concentrate the VOCs up prior to the thermal
oxidiser.
- Flares are often used in the petrochemical industry and are a very simple form of thermal
oxidation generally used when the concentration of gases is above the LEL and not
suitable where the by-products may be toxic or acidic.
HEAT RECOVERY
Heat recovery is not generally an economic option for smaller thermal oxidisers. Larger units
can, however, successfully integrate heat recovery options which may significantly reduce
operating costs and improve environmental benefits. It should be noted that heat recovery is
more difficult for VOC streams containing halogens or sulphur since wet scrubbing is usually
required to remove acidic combustion products. This entails cooling the gases to less than
70C before wet scrubbing and then re-heating to prevent a visible plume.
FIRE & EXPLOSION HAZARDS
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When considering fire and explosion hazards, thermal oxidisers should not be considered in
isolation but as fully integrated system including upstream and downstream plants and
equipment. There are three distinct areas where fire and explosion risks are foreseeable and
demand appropriate measures to reduce these risks to acceptable levels. These are:
- Upstream process plant
- Vent collection system
- Thermal oxidiser
VENT COLLECTION SYSTEM
Vent pipes or ducts carrying the flammable waste stream to the thermal oxidiser for
abatement are also susceptible to being involved in fire and explosion. This can occur if the
solvent concentration conveyed via these vent pipes is not properly managed or monitored
and there is an ignition source present.
There are many potential sources of ignition in a vent header system including:
- Impact sparks
- Flashback from thermal oxidiser
- Pyrophoric materials
- Naked flames
- Electrostatic discharges
- Electrical apparatus
- Mechanical friction
- External sources (e.g. lightning)
- External hot work
Appropriate measures should be taken to exclude all ignition sources wherever possible.
Control of VOC concentration in the vent header system is essential to prevent potential fires
or explosions. Where the basis of safety is operation below the LEL then on no account
should the solvent concentration in the vent collection system exceed 25% LEL unless a
suitable concentration monitoring system is used, in which case the solvent concentration
must not be allowed to exceed 50% LEL. Where solvent vapour concentration is kept above
the UEL, the VOC should be delivered in an inert atmosphere (such as Nitrogen) whenever
passing through the explosive range (UEL - LEL), as would be the case during start-up and
shutdown.
THERMAL OXIDISER
Abnormal operating conditions in the thermal oxidiser can result in an explosion. These
conditions can develop as a result of various deviations described below.
The consequences of an explosion occurring in the thermal oxidiser are potentially lethal due
to explosion overpressure and missiles generated by failure of the casing. These may also
lead to domino effects on adjacent plant. Small explosions may lead to damage either to the
oxidiser shell or the ceramic lining or packing. It is also likely that after an explosion in an
oxidiser a thorough HAZOP and re-design of the system would be needed to the satisfaction
of the competent authority (HSE in the UK) prior to the system being allowed to re-start.
POTENTIAL MALFUNCTIONS
There are many potential malfunctions which may result in fire and explosion hazards in the
thermal oxidiser and vent collection system. Typical of these are:
- Fluctuations in VOC flow rates
- Interruption to power supply
- Process deviations
- Instrumentation problems
- Bringing new vessels or processes on
- Control system problems
line
- Mixing of vent streams
- Reduction in air flow rates
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This risk assessment should be carried out in accordance with the guidance in Ref.16 by a
suitably qualified leader and in the presence of key members of the design team and
operations personnel.
It is essential that the personnel responsible for operating the thermal oxidiser and associated
plants are fully aware of the potential risks and hazards involved in operating the system
especially in terms of the fire and explosion hazards. Information from the risk assessment
process should be cascaded down to operating personnel in order to raise their awareness and
ensure that the plant is operated safely.
HAZOP (HAZARD & OPERABILITY STUDY)
Hazards may arise in a plant due to deviation from the normal operating parameters or
conditions. Hence, a HAZOP Study approach, which is a structured and systematic technique
for identifying hazards and operability problems throughout an entire facility, can be applied
to determine critical parameters that could have a detrimental effect on the plant and the
process.
The list of deviations should form part of the HAZOP study to determine and examine
possible causes, possible consequences, with appropriate actions to minimise the risk of an
incident. Typical aspects considered should include foreseeable changes in normal operation,
equipment, and instrumentation, provision for failure of plant services, provision of
maintenance, safety etc.. It is essential that HAZOP studies be led by a trained and
experienced hazard study leader. The team should include the responsible process engineer,
electrical and instrument engineer, mechanical engineer and plant representative. Other
members may also be required at certain stages, in particular a representative or
representatives of the thermal oxidiser manufacturer who should be fully conversant with the
design, control, operation and limitations of the oxidiser.
A HAZOP or process hazard review should be carried out periodically (5 yearly intervals or
sooner if required) to ensure that the safety and integrity of the system have not been
compromised and that any changes in operating conditions have been taken into account.
Again, this process should be carried out by an experienced hazard study leader.
MODIFICATION CONTROL
It is essential for the continued safe operation of the unit that some form of change control be
exercised. This should include an element of HAZOP in order to ascertain that the proposed
modification does not compromise the safety of the thermal oxidiser, the associated systems
or the upstream plants.
Modification control should also extend to vent header systems and upstream plants and
processes. These modifications should also be HAZOPed to ensure that no additional hazards
or risks are introduced. Modifications should be fully detailed and traceable using a quality
control system.
SAFETY DESIGN OF THERMAL OXIDISERS & VENT HEADERS
Many of the problems that occur with thermal oxidation systems are due to problems with, or
maloperation of the upstream plant resulting in the formation of a flammable mixture in the
vent headers. It is essential that the upstream plant, vent header system and thermal oxidiser
are considered as a fully integrated system and not as isolated units.
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A clear and tenable Basis of Safety for operation should be written for the system. For vent
headers it is not generally sufficient to propose a basis of safety on the absence of ignition
sources since there is always the chance of an external factor as discussed above. The Basis
of Safety for vent header systems should, therefore, be operation outside the flammable
region. The potential consequences of an ignition occurring in the header system mean that it
is critical that a non-flammable mixture is maintained at all times. Design of the system
should be carried out by a qualified and experienced engineering team.
THERMAL OXIDISER SAFETY
THERMAL OXIDISER OPERATION
Under no circumstance should the VOC concentration reaching the thermal oxidiser inlet be
allowed to exceed 25% LEL unless continuous solvent vapour monitoring is provided
upstream of the thermal oxidiser, where a maximum of 50% LEL is acceptable. Operation of
the vent header system above these limits can result in flashback and severe explosion
damage to the vent header system and connected equipment.
If, for any reason, the VOC concentration exceeds these limits then it is essential that
appropriate emergency action is taken. In the first instance this should be to divert the waste
stream to atmosphere. An interlock system should automatically shut down the process in this
event. Only when the cause of the increased VOC concentration has been fully investigated
and conditions rectified and made safe should the system be brought back into operation.
Due to their thermal inertia many oxidisers do not respond well to sudden changes in flows
and compositions. The oxidiser should, therefore, be operated as far as possible under steadystate conditions. It should, however, be noted that flows and compositions can change
rapidly, especially when vessels or processes are brought on line. Rapid changes in waste
stream composition can lead to control system cycling or instability with consequent
explosion hazard.
There are several codes and guidelines which are relevant to thermal oxidiser safety e.g. Refs
6, 7, 8, 9, 10, 11, 12, 13. Refs 27, 32 may also be useful. References 35, 37, 38 discuss the
safety of vent collection and destruction systems.
FUEL TRAIN & THERMAL OXIDATION PROCESS CONTROLS
The thermal oxidiser fuel train and controls must be designed and constructed to recognised
standards in terms of safety e.g. IM30 (Ref.7) and EN 954-1 (Ref. 15). Other codes such as
NFPA 69 (Ref.26) also contain detailed recommendations which may be used by non-UK
manufacturers. Most modern thermal oxidisers incorporate PLC control systems (known as
Programmable Electronic Systems or PES) to control operation. Where necessary, hard-wired
emergency shutdown systems should also be incorporated. Where such PES are used they
should conform to the recommendations in Refs. 22, 23 and 24. Further guidance covering
electrical equipment can be found in Refs 19, 20, 21.
EXPLOSION RELIEF & PROTECTION
It is possible to construct the oxidiser to withstand an explosion however this may be
excessively expensive for larger units and hence is not usually the preferred method of
protection.
Many thermal oxidisers are not fitted with explosion relief but rely instead on high integrity
control and safety systems to reduce the risk of an explosion occurring to an acceptably low
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frequency. Some designs cannot be fitted with explosion relief for mechanical reasons. Often,
this is due to the difficulty of maintaining a gas-tight seal on the explosion relief vent panel
under the high temperatures within the unit. Explosion vents, where fitted, should be located
such that they discharge to a safe location. Explosion relief should be considered for all
thermal oxidisers if practicable. Guidance for the provision of explosion relief may be found
in HS(G) 16 (Ref.32) and NFPA 68 (Ref.25). Further information is available concerning
explosion relief in references 7, 31 and 32 with further information in Refs 17, 18.
VENT COLLECTION SYSTEM SAFETY
The consequences of an explosion in the vent collection system may include:
- Damage to, or destruction of the vent header
- Domino effects on adjacent plant and systems
- Injury / fatality to personnel
Many vent headers are relatively long and pass through areas where personnel or vulnerable
plant are located thus giving a high risk of injury or domino effects in the event of a failure.
Additional protection is, therefore, usually required such as:
- Flame Arresters
- Explosion Relief
- Explosion Suppression
- Fire Extinguishing system
EXPLOSION PROTECTION OF VENT HEADERS
Acceptable VOC concentrations in headers are discussed above. Even so, it is foreseeable for
the VOC concentration to rise to dangerous level under upset or abnormal process conditions.
It is at this time that the plant and its associated ductwork is most vulnerable to fire and
explosion hazards with a high risk of ignition from the thermal oxidiser.
The most common form of secondary protection used is a flame arrester which should be
placed in a position appropriate to the design. There are several designs of flame arrester
available including flat plate, crimped metal and hydraulic. It is essential that the correct type
and specification is used for any particular duty.
It should be noted that flame arresters are not 100% effective. Typical problems are:
- Blockage with particulates
- Polymerisation on arrester elements
- Burn back
- Overheating
Flame arresters are a complex subject and cannot be covered in detail within the scope of this
paper but are covered in Refs 30, 31. Explosion relief is described in Ref 43. Tests of
explosions in pipelines are discussed in Ref 44, 45.
VOC AND OXYGEN CONCENTRATION ANALYSERS
A total unburnt hydrocarbon (VOC) analyser should be provided where necessary as
identified by the risk assessment. The analyser should be of a suitable design and provide
continuous solvent vapour and VOC concentration monitoring. Analysers should meet the
requirements set in Ref. 29.
A maximum safe concentration should be set for the system below the 50% LEL limit which
should trigger a high alarm with a high level trip set above the alarm but below 50% LEL.
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The monitor should initiate the shutdown and emergency diversion systems for the oxidiser.
Shutdown valves and dampers should be of a fast-acting type since concentration can change
very rapidly as a result of process deviations. An oxygen analyser should be used to establish
that the oxygen concentration is less than 1% v/v and thus avert any possibility of forming an
explosive atmosphere.
LEGAL REQUIREMENTS
There are several general legal requirements which cover the safety of the workplace and
equipment e.g. Refs. 1, 2, 3, 4, 5. In particular the following are important:
- Health & Safety at Work Act 1974
- The Highly Flammable Liquids and Liquefied Petroleum Regulations 1972
- The Management of Health and Safety at Work Regulations 1992
- The Provision and Use of Work Equipment Regulations 1992
CASE HISTORIES
Over the years HSE has investigated a number of fire and explosion incidents involving
thermal oxidiser plants. A few of these are given below.
CASE 1
A fire and explosion incident occurred at a chemical plant manufacturing and processing
acrylic resin. Substantial damage was caused to the plant including the ethyl acrylate dump
tank.
The company had installed a catalytic thermal oxidiser for the abatement of ethyl acrylate
vapours (flash point 16C) released in the process as waste. The temperature of the thermal
oxidisers catalyst outlet is temperature was between 350C to 500C. High temperature
should have prompted an alarm and shutdown condition. The incident caused the temperature
to rise to 640C. A flame arrester, provided to prevent fire from propagating upstream, failed
because it was not designed for flowing gas. No solvent vapour analyser was fitted..
Recommendations Included installation of VOC concentration monitoring, re-evaluation of
the capacity of the thermal oxidiser against maximum VOC flows and regular inspection of
flame arresters. Modifications to pipework connections were also required.
CASE 2
Two consecutive fire / explosion incidents occurred at a company engaged in recovering and
cleaning oils for reuse in industry and the automotive trade. The first of the two incidents
occurred inside the thermal oxidiser and the second occurred inside a room upstream where
oil fumes were being generated by a process. Oil fumes were oxidised in a recuperative
natural gas fired thermal oxidiser.
The oil fume feed was bifurcated. One line took fumes into the combustion chamber and the
other was diverted to the base of the thermal oxidisers exhaust stack in emergencies. The
former of the two inlets was fitted with a flame arrester but the latter was not. It was this
which caused the explosion to propagate back through the thermal oxidiser involving the
upstream oil processing room. A number of other irregularities were noted and these
included:
- Little or no knowledge of the hazards associated with the thermal oxidiser
- Absence of adequate temperature control in the oil processing room / storage
- Incorrect thermal oxidiser design
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2. Management of Health and Safety at Work Regulations 1992. Approved Code of Practice
(L21) HSE 1992, ISBN 0 11 886330 4
3. Workplace (Health and Safety and Welfare Regulations) 1992 (L24) HSE Approved
Code of Practice, ISBN 0 11 886333 9
4. Supply of Machinery (Safety) Regulations 1992, SI 1992/3073 HMSO 1992, ISBN
0110257197
5. Provision and Use of Work Equipment Regulations 1992, Guidance on Regulations (L22)
HSE 1992, ISBN 0 11 886332 0
6. Industrial Thermoprocessing equipment EN 746
7. The use of gas in Industrial process plant, British Gas Code of Practice IM 30 1993
8. The Gas Safety Regulations 1972, SI 1972/1178 HMSO, ISBN 0 11 0211782
9. Automatic Gas Burners BS 5885 Parts 1 & 2
10. Automatic flue dampers for use with gas fired heating and water heating appliances
British Gas Code of Practice IM 19 1983
11. Standards of training in safe gas installations, Approved Code of Practice (COP 20) HSE
1987, ISBN 0 11 883966 7
12. EN 746-1, Industrial Thermoprocessing equipment - Part 1: Common safety requirements
for industrial Thermoprocessing equipment
13. EN 746-2, Industrial Thermoprocessing equipment - Part 2: Safety requirements for
combustion and fuel handling systems
14. BS EN 292, Part 1 & 2, Safety of Machinery, basic concepts, general principles for
design
15. EN 954-1, Safety of machinery - Safety related parts of control systems - Part 1: General
principles and design
16. EN 1050 - Principles of Risk Assessment
17. EN 1127-1 (1998): Explosive atmospheres - Explosion Prevention and Protection - Part 1:
Basic concepts and methodology
18. prEN 13478 : Safety of machinery - Fire prevention and Protection
19. prEN 50154 : Electrical Installations in potentially explosive atmospheres (other than
mines)
20. EN 60079-10 : Electrical apparatus for explosive gas atmospheres - Part 10:
Classification of hazardous areas
21. EN 60529-1 : Safety of machinery - Electrical equipment of machines - Part 1 : General
Requirements
22. Programmable Electronic Systems (PES) in safety-related applications: Part 2 General
technical guidelines HSE 1987, ISBN 883906 3
23. Use of Programmable Electronic Systems (PES) in safety-related applications in the gas
industry IGE/SR/15, Institute of Gas Engineers, 1989, ISBN 1367 7850
24. ICE 61508-1 Functional safety of electrical/electronic/programmable electronic safety related systems - Part 1 : General Requirements
25. NFPA 68 Guide for Venting of Deflagrations 1998 Edition
26. NFPA 69 Standards on Explosion Prevention Systems 1997 Edition
27. HSC Publication: Safe operations of Ceramic Kilns, ISBN 0 7176 0630 9
28. prEN 12753:1999 (final draft) - Thermal Cleaning Systems for exhaust gas from surface
treatment equipment Safety requirements
29. EN 1539: 2000 - Dryers and Ovens, in flammable substances are released - Safety
requirements
30. HS(G) 158, Flame Arresters - (Preventing the spread of fires and explosions in equipment
that contains flammable gases and vapours, ISBN 0-7176-1191-4
31. HS(G)11 Flame Arrestors and Explosion Reliefs; HSE Publications
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VOCs
Support fuel
Combustion air
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Reducing zone
Oxidising zone
VOCs
Support fuel
Combustion air
Secondary
combustion air
injection
Combustion zone
Mixing zone
Gas distribution
zone
Combustion air
Support fuel
VOCs
In-line mixer
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Treated
vent gas
Pre-heat
Combustion
Standby
Treated
vent gas
Support fuel
Oxidiser
VOCs
Pre-heater
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