The Code and Common Arc –
Assuring Integrity While Bringing Efficiencies to American Industry
The following presentation was delivered at the 80th General Meeting Monday afternoon session, May 9th, by Jim Pillow. It has been edited for content and phrasing. A slide presentation of his address can be accessed here.
Jim Pillow is chairman of the Operating Committee for Common Arc Corporation. Mr. Pillow has over 35 years' experience as a quality assurance and control specialist in the installation, repair, and maintenance of ASME boilers in utility and industrial power plants. Before joining Common Arc, Mr. Pillow was employed by Ahlstrom Power where he managed the company's quality, welding, NDE, and construction engineering groups. A member of ASME for nearly 25 years, Mr. Pillow has been active in numerous code committees, subgroups, and task groups. He's presently a member of the NBIC Committee, the Committee on ASME Section 1 Power Boilers, and the ASME Board of Conformity Assessment. He is co-author of a soon-to-be-released second edition of Power Boilers: A Guide to Section 1 of the ASME Boiler and Pressure Vessel Code.
What is Common Arc?
Common Arc is an organization formed by the National Association of Construction Boilermaker Employers (NACBE) in January of 1988. It's a not-for-profit corporation dedicated to foster and advance the interests of construction boilermaker employers; promote and further high standards of the construction industry welders; and to develop and maintain a voluntary system for certifying welders.
Common Arc collects and distributes the information needed to maintain welders' continuity. The development and maintenance of the voluntary system is one of the most important keys to the success of the program. It is the cooperation of the participating contractors by agreeing to submit welder history records to maintain a welder's continuity. It also relies heavily on the boilermaker welders volunteering their time to participate in the multiple test sessions. This is done on their time, and without either one of those, the program would really collapse.
Common Arc is managed, if you will, by a board of directors. It has an executive administrator who deals with the day-to-day activities. The board of directors and the executive administrator are supported by two committees: the executive committee and the operating committee, which I chair. The board of directors is made up of representatives of the participating contractors and boilermakers. The president of the board is a participating contractor. The executive administrator today is John Erickson, and the executive committee is comprised of the board of directors' president as well as the secretary-treasurer, and they assist the executive administrator on making funds disbursements and that sort of thing.
The operating committee acts primarily in an advisory role to both the board of directors and the executive administrator. They provide direction for upgrading the program based on changes in industry needs, advances of welding and data management and technology, as well as Code 210 changes.
How Did it Get Started?
In the mid-1980s, a small group of owners, contractors, and boilermaker representatives got together and asked, “What can we do to improve efficiencies at the job site?” It was agreed, among other things, that if everybody cooperated, multiple test sessions and maintenance of welders' continuity would benefit everybody, and it was doable.
Most of us here today probably remember the 1980s and the big transition that happened with the design, manufacture, and installation of large steam-generating process power plants – primarily coal-and gas-fired, but some nuclear. Well, designing those large utilities and long-term projects went away somewhere in the mid-1980s, and it went from that to managing large, short-term and intense maintenance programs.
One consequence of this change was the frequent loss of welder process continuity. If a welder – then, as now – did not weld with a process within six months, continuity was lost. And because of the scheduling of maintenance outages, it was inevitable that process continuity would be lost and the welder would have to take a qualification test at nearly every outage for every employer, and often for the same employers from the previous outage. This hurt everyone.
Contractors had to give multiple tests and welders were put at risk of not passing a test; thus no job, and this was done often after traveling hundreds of miles to the job site. Remember those days? And the owner's outage was lengthened due to nonproductive hours spent on repeated testing of welders. If this could be resolved, it would help everybody.
How did that happen? We talked a little bit about how the National Board Inspection Code (NBIC), as well as ASME, helped provide these efficiencies to American industry. Like any new thing that comes along, the first pushback for those of us who have been involved in committees is, “This is new and different. Is it allowed by the code?”
Once the pushback came from early developers, it was decided that it met the code and it could be done, but it was also decided that we needed a little backup. So we went to the National Board. But before describing that, I want to mention a few names of those early developers who deserve some credit. In fact, I know they deserve credit. The first is Alan Bell. At that time he was a member of the International Brotherhood of Boilermakers. He's now with Ahlstrom Power and is still a member of Section 9. Other include Perry Gay, who was also a boilermaker representative; Wayne Johnson, who was with B&W Construction at the time and is now retired; Bill Kunkel, who is a retired president of Enerfab Corporation and past chair of the Operating Committee; Bill Gordinier, who ran Gordinier Associates, volunteered to maintain the database and did a fine job; and John Erickson, who at the time was president of National Association of Construction Boilermaker Employers (NACBE) and with Babcock &Wilcox and is now the executive administrator. And I need to mention Nino Olivares, who is with Hartford Steam Boiler and is still a member of Section 9.
I was also involved in the early days. At that time I was with Combustion Engineering, which is now called AP Com Power. They are a construction division. But as I was saying, we needed backup, so we went to the National Board, and they responded by saying that the process was not prohibited, which in code speak means, “proceed at your own risk.” And it's my understanding Bob Schueler of the National Board was the individual who rendered that opinion, and in talking with him earlier he said he paid with a pound of flesh for rendering it. There were a lot of people who did not agree with him, obviously.
In any case, when we received feedback from the National Board, it was decided to proceed, but it would only be used on repairs performed in accordance with the National Board Inspection Code. In 1986, Section 9 helped out by substantiating the National Board's opinion. They issued this interpretation, per QW-300.2: “May several contractors simultaneously conduct the performance qualification tests of a welder?” Section 1 again, along similar lines, says: “We do not address this,” meaning, “We don't approve it. We don't not allow it (it's not prohibited), we just don't address it.”
Second interpretation along the same lines: “May a welder weld simultaneously with a WPS of several contractors when the essential variables are documented as equivalent?” Again, they did not address this situation. This certainly helped the organization, but again, we were basically told to proceed at our own risk. So we did, and we still restricted the program to repairs done in accordance with the National Board Inspection Code.
We still pursued code support for the organization, and in 1989, Section 1 issued the interpretations by basically asking the same questions we asked the Section 9 and the National Board, but Section 1 responded in both cases with the reply, “Yes, you can do this.” There was no doubt about it.
Of course, this helped a great deal, and the program was then used for Section 1 construction as well as repairs and alterations performed in accordance with the National Board Inspection Code. However, this did not please everybody. The efforts continued to get true code rules, and because some thought (and rightfully so) that this was an example of code rules by interpretation, there had to be some definite rules before the program could be accepted by all.
That came around 1992 when Section 9 issued a revised QW-300.3 with the rules addressing simultaneous testing of welders. It said, “You could do this.” One rule was to have to have WPS essential variables be identical except for pre- and post-heat requirements.
A single WPS could be selected by the contractors; however, the contractors must have supporting procedure qualification records for that procedure. When a welder changes employers, the new employer must verify continuity has been maintained. And if the welder is revoked, the qualification is revoked by any of the participating contractors; the other contractors must be advised. It had taken over six years to achieve this, but finally the code rules legitimized the Common Arc program, and we proceeded for new construction as well as repairs and alterations.
We have been around for almost 25 years – so how do we go about assuring the integrity of the program? The first and probably most important thing is that rules were established by the ASME code that have to be followed by everybody who wishes to participate in a program similar to Common Arc's. Conformance to the rules is assured by a number of rules and agreements each participating contractor must follow.
Participating contractors start by signing an agreement with Common Arc stating they will abide by program rules. And they also have to certify that they have a written quality control (QC) program with provisions for assuring welder qualifications and maintenance conform to Section 9.
If contractors do not meet program requirements, they are not allowed to participate. Those not adhering to the rules are removed from the program roster of participating contractors. This is a rare occurrence, but it has happened.
Each participating contractor has several options as far as meeting these regulations. By far, almost all participating contractors have either a National Board or an ASME Certificate of Authorization. A copy of this authorization is maintained on file by Common Arc, and we candidly rely on the National Board and ASME's triennial reviews and renewal of those certificates as far as their performing the assessment goes.
In lieu of National Board or ASME certificates, they can have an ISO program certified by a registrar recognized by the Registrar Accreditation Board. I don't think we have any participating contractor relying on this particular requirement, but if they do, a copy of the certificate is maintained. We rely on the registrar's periodic reviews and recertification on that contract to show their ability to conform to the rules.
I believe we have one participating contractor that has a 10CFR50 Appendix B quality program. When that happens, a copy of the portion of the program addressing welding control is submitted. We select an authorized inspection agency (AIA) to review and state whether it is an acceptable program, and a copy of the AIA approval letter is maintained on site. The last option as far as the QC program goes is that they can have a written program stating and addressing control of welding in accordance with Section 9. The contractor's program is audited on a triennial basis by an authorized inspection agency selected by the operating committee, and the report is maintained on file. Now, as you might imagine, not all participating contractors work on pressure vessels or boilers. We do have one participating contractor meeting this requirement, and they are scheduled for an audit.
Test Session Proctors
What actions does Common Arc take to assure this integrity? We have about 30 proctors who report to the executive administrator. Usually three are there and more are at multiple test sessions where needed. But at test sessions, the proctors or the lead proctor provides orientation and instructions to both the contractors and the welders.
Proctors assure adequate equipment and supplies are available during multiple test sessions. They monitor the process, which is key to assuring that witness points are observed, test coupon identity and traceability are maintained, and paperwork is completed and sent to Common Arc.
Another step Common Arc takes to assure integrity is internal reviews. Periodic reviews and assessments of multiple test sessions are performed to ensure rules are being followed, et cetera. This is performed by the operating committee. The report is issued to the executive administrator and maintained on file, and actions taken are recorded for any deficiencies noted during those reviews.
Along with code rules, our annual program audit is very important. The audit is performed by a team led by a representative from one of the participating contractors. It includes a representative from the jurisdictional authority, a boilermaker (usually from the international office), and an authorized inspection agency representative. The report is maintained on file, as well as the executive administrator’s response to the report.
As I have stated, the team is led by a contractor representative. We have had various contractors in this role, and last year we were very pleased to have Ruben Child from PPL Generation, who is considered a participating contractor to lead that audit, and he brought a much-appreciated owner's perspective to it. For the first fifteen years or so, Richard McGuire of the National Board was a team member. Since his passing, the team has included chief inspectors from Tennessee, Indiana, California, and last year Gary Scribner of Missouri was a member. This year the chief from Illinois has agreed to participate as a team member. Additionally, Nino Olivares has been involved on the audit team almost from the start. Last year Nino did not make the audit and was replaced by Bob Wielgoszinski, who happens to be the 2010 recipient of the National Board Safety Medal Award. So we have tried to bring together a true unbiased audit team, and they do a fine job.
Efficiencies to American Industry
How do we bring efficiencies to the American industry? Focusing on how we could speed things up and make outages shorter and less expensive is really how this whole thing got started. Well, to date we have over 200 participating contractors. There are over 12,000 welders in the program. Ten thousand of those welders, or more actually, have both the GTAW and SMAW process certifications, and there are actually over 60,000 individual qualifications maintained in our database.
It’s noteworthy to mention that almost every welder in the program has multiple qualifications for multiple contractors. They have plate and tube qualifications, Flex-Core, gas metal arc, TIG and stick certifications, manual and semiautomatic methods, as well as multiple filler metals, low alloy, Inconel and stainless steel.
Common Arc facilitates compliance with QW-300.3 by facilitating multiple testing sessions. Monthly welder qualification maintenance reports are issued to each of the participating contractors. We advise contractors when a welder is removed from the list by a participating contractor, and we provide access to those records via the internet and the Host On-Demand process. Last year there were over 5,000 welders tested. And as far as the cost last year, it costs about just under $23.00 to test the welder; it costs just under $5.00 to maintain continuity for the first year. The cost after that is $5.00 a year to maintain the qualifications. And based on estimates provided by the participating contractors, it's estimated that testing at the job site would be about $865. That's probably closer to a $1,000 today; this was done a few years ago.
I'm going to give an example of the actual impact on a job that's not unusual. It's based on input from our participating contractors, and it's what is termed a typical project. It's not unusual to have 200,000 man hours (a cost of about $10 million dollars in payroll costs) based on $50.00 an hour if you have 100 boilermakers for 40 hours for 50 weeks, and a crew of about 100 boilermakers consisting of 55 mechanics, general foremen, foreman, and about 45 welders.
Based on the data gathered at our testing sessions now, the average passing rate is just over 47 percent. I want to address this because it has gone down over the years due in large part to the demand for welders in the industry. Prior to two years ago, a boilermaker apprentice could not take his welding certification until his fourth year. They changed the rule, so now because they were recruiting, they would allow a boilermaker apprentice or someone in the program to take the test the first year.
As a consequence, there are a lot of people who just don't have the training and experience, so the acceptance rate has gone down. Based on that, at the job site a contractor would have to test 95 welders in order to get 45 with a cost of just over $82,000.
Without Common Arc you would have a cost of $82,000, and perhaps even more important to the owners is that you have 760 hours lost production. Welders from the Common Arc program can go to the job site and go right to work.
Moving forward we are going to continue facilitating compliance with Section 9 rules. We will continue with the internal and external conformity assessment practices of both Common Arc and the National Board and ASME. We will continue the ongoing efficiencies, and right now we have about 16 (unless we have added more), but we anticipate having about 45 multiple test sessions this year located all over the country – from California to Maine, Louisiana to Minnesota.
If you are interested in more information, feel free to contact us. Call us if you would like to talk in person. You can go to the website and download a copy of the program manual. Thank you very much.