MEMORANDUM

TO: R. Arthur, S. Gallagher, L. Schaider DATE: 03 October 2001

J. Houston, M. Valle Memo No. 60

FROM: Urey R. Miller

SUBJECT: Usage of the Terms Lethal Service, Lethal Substance,

Category M Fluid Service, and Toxic Fluid

We regularly encounter process services that potentially could be classified as a "lethal

service" or "Category M Fluid Service". These terms have the sole purpose of
specifying certain ASME rules of construction.

The purpose of this Memo is to clarify KBR's role in the application of the ASME's
usage of the above terms. Please distribute this Memo as appropriate.

Beyond the scope of this Memo are procedures and equipment that may be required to
mitigate potential leaks of hazardous substances. Likewise, this Memo does not
address the use of government and industry unique definitions and applications of
terms such as NFPA's Health Hazard 4, "IDLH (Immediately Dangerous to Life or
Health)", OSHA's "Highly Hazardous Chemicals", DOT's "Poisonous Gas", API's "Acute
Toxicity Concentration", building code definitions of "toxic" chemicals, LC50, etc. These
terms generally have limited meanings and are used to address specific objectives
within the scope of their use.

The Engineering Safety Checklist for Process Design asks, "have any potentially lethal
substances or Category M fluid services (as defined by relevant ASME Boiler and
Pressure Vessel or Piping Codes) been identified by the client?"

Where lethal services are identified for ASME Section VIII, Divisions 1 and 2, or
Category M fluid service for B31.3, these Codes have established specific rules for the
design and fabrication of the pressure boundary components.

ASME B&PV Code, Section VIII, Division 1. Section VIII uses the terminology "Lethal
Service" and "Lethal Substance" as factors to be considered and defined by the user of
the pressure vessel or his designated agent to establish specific design and fabrication
requirements:

The user or his designated agent shall establish the design requirements for
pressure vessels, taking into consideration factors associated with normal
 operation such other conditions as startup and shutdown, and abnormal conditions
which may become a governing consideration (see UG-22). Such consideration
shall include but shall not be limited to the following ...

(2) the definition of lethal services. For example, see U-2(a)(2) and UW-2(a).

For this Division, the user's designated agent may be either a design agency
specifically engaged by the user, the Manufacturer of a system for a specific
service which includes a pressure vessel as a part and which is purchased by
the user, or an organization which offers pressure vessels for sale or lease for
specific services.

UW-2(a) sets out certain criteria for vessels which are to contain lethal substances,
either liquid or gaseous. A footnote to UW-2(a) --

By "lethal substances" are meant poisonous gases or liquids of such a nature that a
very small amount of the gas or of the vapor of the liquid mixed or unmixed with air is
dangerous to life when inhaled. For purposes of this Division, this class includes
substances of this nature which are stored under pressure or may generate a
pressure if stored in a closed vessel.

Division 2 uses similar criteria and definitions at AG-301.1(c).

ASME B31.3 paragraph 300(b) sets out the responsibilities of the owner, designer, and
others:

(1) Owner. The owner of a piping installation shall have overall responsibility for
compliance with this Code, and for establishing the requirements for design,
construction, examination, inspection, and testing which will govern the entire
fluid handling or process installation of which the piping is a part. The owner is
also responsible for designating piping in certain fluid services. [See paragraphs
300(d)(4) and (5) and 300(e).]

(2) Designer. The designer is responsible to the owner for assurance that the
engineering design complies with the requirements of this Code and with any
additional requirements established by the owner.

B31.3 300(d)(4) refers to Category M fluid service:

For piping in a fluid service designated by the owner as Category M (see para. 300.2
and Appendix M), all requirements are found in Chapter VIII. (Paragraph
designations begin with "M.")

Category M Fluid Service is defined at 300.2, definitions, under the term fluid service:

A fluid service in which the potential for personnel exposure is judged to be

significant and in which a single exposure to a very small quantity of a toxic fluid,
caused by leakage, can produce serious irreversible harm to persons on breathing
 or bodily contact, even when prompt restorative measures are taken.

B31.3 Interpretation 1-40 emphasizes the owner's authority/responsibility for

designating piping in Category M Fluid Service:

Question: What constitutes "a very small quantity" in the definition of Category M
Fluid Service, in 300.2?

Reply: "A very small quantity" is the amount determined by the owner to be
significant in his identification of a Category M Fluid Service. See 300(b)
(1).

Since the use of the “lethal” or “Category M” classification results in specific

vessel/piping design/ construction criteria, these determinations have meaning only in
the context of the Codes in which they are used, and are pertinent only for the definition
of design and fabrication requirements.

For ASME Section VIII applications, “lethal service” generally means that full
radiography is required, PWHT for ferritic material, limitation on some types of welded
joints, and the prohibition of brazed construction, such as brazed aluminum heat
exchangers. This is essentially the extent of the requirements.

ASME does not set out "quantitative" definitions such as "500 ppmv fatality threshold"
in these Codes. It is intended that the owner have flexibility in establishing what
services in which he elects to invoke these requirements based on his experience and
consideration. Since establishing a pressure vessel's service requirements are clearly
the client's, we, KBR, have tried to avoid providing a firm definition for "Lethal" and
"Category M" services.

Where potentially lethal services are being handled, we specifically request guidance
from the client. This is very important because the client must weigh how such a
classification may affect his other facilities handling the same material. If we categorize
a unit as "lethal service" and "Category M Fluid Service" and his other similar units are
not so designated, we have created an inconsistency for him that may be a problem. It
is not appropriate for a contractor to determine these classifications without input and
guidance from the client.

If the service conditions were not defined as lethal or Category M in the bid documents,
we should not take it upon ourselves to make this determination. However, it would be
appropriate to confirm to the client that we are proceeding on the basis that this facility
has not been categorized by him as involving lethal service or Category M Fluid
Service. In the past we have issued the following statement for this purpose prior to
process release:

"The current KBR work process requires that we address specific service
requirements of the ASME Boiler/Pressure and Piping Code requirements with the
owner. The ASME Code requires that the owner define services conforming to the
following:
 o "... poisonous gases or liquids of such a nature that a very small amount of the
gas or the vapor of the liquid mixed or unmixed with air is dangerous to life when
inhaled", or

o "a fluid service in which the potential for personnel exposure is judged to be
significant and in which a single exposure to a very small quantity of a toxic fluid,
caused by leakage, can produce serious irreversible harm to persons on
breathing or bodily contact, even when prompt restorative measures are taken.

Such services are defined by ASME respectively as "lethal service" and "Category M
Fluid Service", and specific design and fabrication requirements apply. Unless
otherwise instructed, KBR is proceeding with the specification and procurement of
pressure vessel and heat exchanger equipment on the basis that there are no ASME
defined "lethal service" or "Category M Fluid Service" conditions that apply on this
project.

If you disagree with this assessment, please advise us."

Should the client disagree, further direction from the client would be required.

Regarding the specific substances, it is generally accepted industry practice that CO

and H2S, even in % concentrations, are not typically categorized by our clients as
either lethal service or Category M Fluid Service. Hydrogen cyanide, phosgene and the
like are typical candidates for these service designations.

If you have any questions or comments, please advise me.

Urey R. Miller, P.E.

KBR Chief Engineer, Cullen Center
Ext. 7393

URM/ft

Cc: T. Challand
G. Moore (for PM Network Distribution)