Once again, auditing pays off! No way in heck, my audits should be the method to identify QA failures on a piping installation, but it seems the past 10 years or so, it’s happening more and more. This event was a significant failure on the General Contractor and the Sub-Contractor, who was doing the actual welding. This is the corrective action plan I offered to the client for recovering from these failures. Company names and welder names have been removed – it’s about learning from the mistakes of others, NOT name shaming.
1) The EXCEL spreadsheet that XXXXXXX provided states that the welders’ certificates for XXXXXXXX and XXXXXX will NOT be available until Tuesday, 4/21/26. So XXXXXXXX and XXXXXX are NOT certified to begin pipe welding until those documents are received and approved by the Management of XXXXXXXXXXXX by signing them and dating them, as well as signing and dating the WPS that they will be a party to (the records from last week are not signed and dated as required).
2) XXXXXXXXXX attached a WPQ for XXXXXXXXXXX, who is no longer with the company, based on the information contained in the XCEL file provided. We need to WPQs for XXXXXXXXX, XXXXXXXXXX, and XXXXXXXXX. Each welder’s WPQ must be signed and dated by the company representative responsible for the company’s Welding Quality Assurance (QA) program.
3) I am sorry that my comments have been misunderstood, but the 26% rejection rate (which is actually higher) is a FAILURE that has to be addressed. In no way did I intend my comments to be favorable enough for us to continue on the current path.
“Furthermore, as Bryan mentioned, since the final RT results and pressure test results validate the quality of the previous work, we believe there will be no issues from a long-term perspective.”
- 3.a. XXXXXXXXX should provide us with a corrective action plan (CAP) as to how they are going to manage any rejection rate over 3% per welder.
- 3.b. XXXXXXXXX needs to explain why they did not STOP all pipe work upon receiving the RT examination results on 3/29/26.
- 3.c. We need to see the written plan for how they repaired the rejected welds (who, when, and the RT results for ALL repaired welds).
- 3.d. Was XXXXXXXXX recertified on his/her weld(s) after this rejection rate of over 5%?
- 3.e. XXXXXXXXXXXXX needs to come clean on the fact that it’s possible non-certified welders were allowed to make pipe welds, and if so, how many, which welds, and what is the plan to correct this oversight error?
- 3.f. XXXXXXXXX must identify the QA manager under the WPS and how they will ensure that ONLY qualified/certified welders perform welding on pipe circuits.
4) We need to understand the welding QA system for XXXXXXXXXXXXXX
- 4.a. Who is responsible?
- 4.b. How is each weld being identified as to who made each weld (stamping, weld map(s) – ISOMETRIC drawings)?
- 4.c. How are they distinguishing their welds from welds made by UPS?
NOTE: Should there be an accident associated with a pipe weld failure, the first thing an investigator is going to ask for is the welding records associated with that weld. There MUST be a very clear tracking system for which company made the weld, which employee under that company made it, their certification to make it, and how the weld was validated, pressure-tested, and leak-tested. This should take no more than 5 minutes to provide to an investigator/inspector.
5) XXXXXXXXX should establish an auditing schedule for XXXXXXXXXX (the GC) to audit the pipe work at some frequency to ensure that XXXXXXXX is meeting the code and LH requirements. XXXXXXXXXX personnel should randomly spot-check the number of workers observed making welds on piping against the number of certified welders associated with the WPS for the work. For example, we will have three (3) certified welders on the WPS by 4/21//26. When we walk into a XXXXXXXXX room (North or South), we should see NO MORE than three (3) welders working on piping (fab area and installation). If we find a deviation from this, the work is shut down, and an investigation ensues. At this juncture, if it were my plant, I would want a picture of XXXXXXXXXXX, XXXXXXXXXXXX, and XXXXXXXXXX, and I would require them to have some form of Identification on their person so we can adequately verify that they are who they say they are. On large projects, this is a common practice. It’s not required; it’s part of how we conduct our own auditing/spot-checks.
6) Due to the severity of the risks associated with pneumatic pressure testing and the issues to date, XXXXXXXXXX should request a copy of XXXXXXXXXX’s written pressure test program/procedure to ensure it fully complies with ASME B31.3 and ASME PCC-2. This XXXXXXXXX piping is large-diameter and poses catastrophic risks during pressure testing. We need to understand
- 6.a. How the piping being tested will be ISOLATED from other parts of the process
- 6.b. The method of pressure testing to be done (pneumatic/hydrostatic),
- 6.c. The pressure that will be used for the pressure test and the pressure that will be used for the sensitivity leak testing,
- 6.d. What the testing media will be (CDA, N2, Ar, etc.),
- 6.e. What is the safe distance for the pressure testing phase of the work