Unlisted Orbital Weld Procedure and Expired Test Gauge
A repair organization's QC manual, revision 7, lists manual gas tungsten arc welding and shielded metal arc welding but not automatic orbital welding. In March, a certified welder used a new orbital welding procedure, qualified by procedure qualification record in January, to repair a 6-in. NPS feedwater line on a boiler. The welding engineer approved the procedure by email but did not revise the QC manual. In April, an NBBI audit also finds that a dial pressure gauge used for a hydrostatic test had a calibration sticker expired by 60 days; the authorized inspector had accepted the test. The shop wants to update the manual retroactively to include the orbital process and keep the repair report valid. The audit is still open, and the shop has two other repairs scheduled this month using the same procedure.
1. What QC manual and procedure-control requirements did the shop violate by using the orbital procedure before revising the manual?
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The shop used a welding process that was not described in its approved QC manual and had not been incorporated through the manual revision process. A procedure qualification record by itself does not authorize production use; the QC manual must identify the process, the procedure, the essential variables, and the approval and revision controls. An email approval from the welding engineer is not a controlled manual revision unless the QC manual specifically allows that method and the change is documented and approved by the required authority.
The violation matters because the manual is the shop's written description of how it controls repair work. Using an unlisted process means the repair was performed outside the approved quality system, and the authorized inspector was not given the correct procedure to review. The shop should stop using the orbital procedure until the manual is revised and approved and the inspector has reviewed the change.
2. How should the expired gauge calibration affect the hydrostatic test and the repair documentation?
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The hydrostatic test was performed with an instrument that was not within its calibration interval. That is a calibration nonconformance, and the test result cannot be accepted as valid merely because the authorized inspector witnessed it. The inspector's acceptance does not cure an expired calibration sticker.
The shop should open a nonconformance report, quarantine or recalibrate the gauge, and determine whether the test can be repeated or verified with a calibrated gauge. If the test cannot be repeated, the shop must evaluate whether the repair can still be accepted by other means acceptable to the inspector and jurisdiction. The affected repair report should not be signed off as compliant until the test validity is resolved. The shop should also review other tests performed with the same gauge during the expired period.
3. What corrective actions and report disposition are appropriate before the audit closes?
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The shop should contain the problem first: stop production use of the orbital procedure until the QC manual is revised and approved, and remove the expired gauge from service. It should review the March repair and the two scheduled repairs to determine whether they were or will be performed under an approved procedure. For the March repair, the shop should notify the authorized inspector, evaluate the weld records, and perform any additional examination needed to support acceptance. The R-1 report should be signed only after the inspector is satisfied with the procedure control and test validity.
Root-cause corrective action should include revising the manual through the controlled process, training welders and supervisors, updating the calibration recall system, and auditing recent repairs for similar issues. The shop should not backdate or retroactively make the email approval look like a manual revision. It should document the correction honestly and respond to the NBBI audit findings.