API 754 Acid Base Revisions Proposal Team Vito

API 754 Acid Base Revisions Proposal • Team: • • Vito Bavaro – Lead Jim Muoio Rodney Reibold Wayne Howard

API 754 Acid Base Revisions Proposal Going into May Meeting 5/20/20 1. Prioritize use of GHS skin corrosivity as the primary characterization in the definition. PH will be mentioned when skin corrosivity is not available. 2. Indicate to not use packing group at all for acid/bases. Just GHS and PH (Simplification) 3. Remove the indoor/outdoor threshold differences and go with outdoor thresholds. (Relevance) 4. Do not add complexity of characterizing corrosivity damage to equipment/direct cost. (Do not add more complexity) 5. *Secondary containment “safe” release”.

GHS Skin Corrosovity and PH for Strong Acids/Bases • From…. • Strong Acids/Stong Bases: Substances with PH>1, or PH <12. 5, or more precisely, substances that cause full thickness destruction of intact skin tissue with an observation period up to 60 minutes starting after the exposure time of 3 minutes or less, consistent with Global Harmonized System of Classification and Labeling of Chemicals (GHS) Skin Corrosivity Category 1 A To… • Strong Acids/Strong Bases: Substances with Global Harmonized System of Classification and Labeling of Chemicals (GHS) Skin Corrosivity Category 1 A. This is consistent with substances that cause full thickness destruction of intact skin tissue with an observation period up to 60 minutes starting after the exposure time of 3 minutes or less. The intent of this classification parameter is to represent the personnel risk exposure to burns that could result from an LOPC of this material. When GHS skin corrosivity is not readily available, an alternate classification which uses PH<1, or PH >12. 5 is acceptable.

GHS Skin Corrosovity and PH for Moderate Acids/Bases • From…. • Moderate Acids/Stong Bases: Substances with PH>=1 and < 2, or PH >11. 5 and <=12. 5 , or more precisely, substances that cause full thickness destruction of intact skin tissue with an observation period up to 14 days starting after the exposure time of 60 minutes or less, but greater than 3 minutes, consistent with Global Harmonized System of Classification and Labeling of Chemicals (GHS) Skin Corrosivity Category 1 B To… • Moderate Acids/Bases: Substances with Global Harmonized System of Classification and Labeling of Chemicals (GHS) Skin Corrosivity Category 1 B. This is consistent with substances that cause full thickness destruction of intact skin tissue with an observation period up to 14 days starting after the exposure time of 60 minutes or less, but greater than 3 minutes. The intent of this classification parameter is to represent the personnel risk exposure to burns that could result from an LOPC of this material. When GHS skin corrosivity is not readily available, an alternate classification which uses with PH>=1 and < 2, or PH >11. 5 and <=12. 5, is acceptable.

Use of Packing Group for Acids/Bases • Use of packing group classification was challenged for acids/bases. • GHS/PH are readily available and are considered better methods for skin corrosivity intent. • Relevancy, Duplication, and Simplification are reasons to remove

Indoor/Outdoor Threshold Differences • Remove the indoor threshold quantity and just maintain outdoor threshold quantity for Acids/Bases. • Relevancy of Indoor threshold for acids/bases was challenged. • If there is a toxic component that becomes relevant, it is classified via other measurement first before being classified as an acid/base.

Corrosivity damage to equipment/direct cost • Adding the damage caused by corrosivity was proposed to equipment damage/direct cost was proposed. • Do not add corrosivity damage to equipment/direct cost. • Adds more complexity. • Doesn’t mesh up with current definitions of…the damage caused by an LOPC from the fire/explosion.

*Secondary containment for Acids/Bases. • Proposal for non tierable acid/base LOPC when it goes to low risk open secondary containment. • If a leak occurs which is characterized as a moderate or strong acid/base (not toxic or other characterization) and…. • The amount released exceeds the threshold quanity and… • It exceeds the capacity of the designed open secondary containment system and amount in excess exceeds the threshold quantity OR…. • A person is exposed/sprayed by and acid/base LOPC OR… • If someone is present within the designed open secondary containment system, when the leak occurs (this raises the risk potential of such an event) • Other criteria for designed secondary open containment is that controls must be in place (signage, flagging, PPE requirements) to allow this criteria to be applied OR…. • If an injury or direct cost criteria occurs per other API 754 criteria • Then these criteria would make it an API Tier 1 or 2. • Otherwise, it is not tierable when a leak goes into open secondary containment.