PVS Position Regarding Treatment of Miss-Located Holes

BNI P.O. 24590-QL-POB-SS01-00002 Rev 41

Mark V. Holland, P.E.

Chief Engineer
Paxton & Vierling Steel Co., Omaha, NE

The following is an explanation of the treatment and methodology used by PVS when a
mislocated hole is found in a member.
The referenced sections of the governing industry documents are:
• AWS D1.1:2000 Section 5.26.5 Weld Restoration of Base Metal with Mislocated
Holes
• ANSI/AISC N690-1994 Section Q1.23.11.3 Holes
• ASTM A6-08 Section 9.5 Repair by Welding.

PVS Understanding of the direction provided by AWS D1.1:2000:

Section 5.26.5 of the AWS D1.1:2000 has three options to use when a mislocated hole
is found and states:
“Except where restoration by welding is necessary for structural or other reasons,
punched or drilled mislocated holes may be left open or filled with bolts.”
• PVS has interpreted this sentence to mean that unless the presence of the hole
creates a concern regarding the ability of the member to carry or transfer load
leaving the hole open is the best course of action.
• The same sentence says that the hole may also be “filled with bolts”. PVS has
interpreted this to mean that if for reasons of appearance it is not acceptable to
the owner to have unused open holes, the hole will be filled with a fully tightened
bolt.
• The last sentence of the first paragraph of this section says “When base metal
with mislocated holes is restored by welding, the following requirements apply.”
PVS has interpreted this to mean that since the first two conditions are not
acceptable it implies that the engineer has structural or other reasons to require
the holes be filled. When this issue was originally discussed in 2002 and 2003
with BNI, PVS was directed by BNI to always fill the mislocated hole.
Under this BNI directive, the fabricator is required to review the applicability of AWS
DI.1.2000 subsection (1) “Base metal not subjected to cyclic tensile stress …”,
subsection (2) “Base metal subject to cyclic tensile stress…” or subsection (3) “…holes
in quenched and tempered base metals…”. Since the base metals are not quenched or
tempered steels ~ neither subsection (1) or (2) apply.
PVS is currently using the BNI approved hole repair procedure “Hole Repair rev 0”
dated 03-27-03 (24590-QL-POB-SS001-00002-03-21 Rev 00A)

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 • On page 1 of 2 of this procedure PVS specifies the joint type, base metals that
are applicable, filler metal specification and classification, shielding gas, preheat,
position, electrical characteristics, technique, and welding procedure.
• On page 2 of 2 of this procedure PVS lists in the memo section nine (9) steps
necessary to correctly make the needed repair. This procedure satisfies the
requirements of either subsection (1) or (2) and identifies ultrasonic inspection as
the NDT method used to verify the restoration of the base metal.
• Not listed in the steps on page 2 of 2 but done on every mislocated hole is the
action taken by PVS to write an internal NCR for each occurrence. These PVS
NCRs and the associated UT report are sent to the BNI PAAA coordinator and
the BNI RE assigned to PVS. The scope of information captured on these NCRs
identified the cause of the mislocated hole and the corrective action taken (For
example to provide additional training to an equipment operator if operator error
is found to be the cause.).
PVS has interpreted this entire section to say that when directed by the engineer that
either leaving an hole open or filling the hole with a bolt is not acceptable ~ Section
5.26.5 of the AWS D1.1:2000 must be used to provide direction to PVS for the proper
method of restoring the base metal to an acceptable condition.
Given the BNI directive was to always restore the base metal by welding, it follows BNI
deemed the location of the mislocated hole not to be relevant.

PVS Understanding of the direction provided by ANSI/AISC N690:

Section Q1.23.11.3 Holes in the N690 document says “In compression members
erection holes and holes mispunched or misdrilled may be left unfilled provided the net
area is not less than 0.85 times the gross area. In the case of tension members they
may be left unfilled provided the net area requirements are met.” PVS interprets this to
say that unless these two conditions are violated a mislocated hole should be left
unfilled.
• In the case of compression a hole would have to remove 15% of the member’s
area which is not practical for a normal bolt hole.
• In the case of a tension member PVS has concluded that since any given part
with a mislocated hole has a designed hole and therefore the engineer has
already checked the net area requirements.
This information was available in the discussions in 2002 and 2003 between PVS and
BNI, and the subsequent direction from BNI was to always restore the hole regardless
of the conditions provided in this document.

PVS Understanding of the direction provided by ASTM A6-08:

Section 9.5 Repair by Welding in the ASTM A6-08 provides guidance to the mills on
how to properly repair a number of imperfections in raw material before it is shipped to
the contractor.
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Although this document does not directly discuss the restoration of a mislocated hole, it
does provide some guidance regarding general repairs. The subsections in this
document discuss welding requirements such as the use of a written WPS, matching
filler metals with base metals, proper storage and handling of the filler metal, inspection
and cleanliness of the repair area, use of qualified welders, appropriate testing of the
repaired area, and when so specified in the purchase order approval from the buyer of
the of the weld procedure.
Additionally Subsection 9.5.1.7 (2) says “The geometry of the surface groove weld need
not be described in other that a general way.”
PVS has interpreted this information to say that raw material can be restored to an
acceptable condition by welding if proper procedures are followed. However since all
welder qualifications and WPSs are subject to approval of the buyer, PVS does not
allow the mills to make these types of repairs. It is not practical for PVS to maintain and
gain the approval of the welder qualifications and WPS of all the various mills involved
in the supply of the members to the project.
It is worth noting that the subsection 9.5.1.7 (2) deemphasizes the geometry of the
groove weld used in the repair.
PVS’ general interpretation of this document is that the base metal can be restored to
an acceptable condition as long as proper weld processes are followed.

PVS Understanding of the required documentation for the restoration of base

metal:
It is PVS’s understanding that the controlling section from the P.O. is in the specification
Purchase of Structural Steel (24590-WTP-3PS-SS01-T0002, rev 10) Section 6.1.6.1.
This section reads “Controls shall be established and implemented, with objective
evidence through suppliers records, to ensure that only correct and accepted items and
materials are used. Consumed filler material lot or heat numbers shall be documented
on one or more of the following records: drawings, weld maps, shop travelers,
inspection reports, etc.”
For the issue of the restoration of the base metal because of a mislocated hole the
material that must be controlled and documented is the filler metal used in the repair.
For all welding, the practice followed at PVS to control the filler metal is to have only
one lot or heat of an acceptable filler metal wire is in use on the shop floor at a time.
This is accomplished at PVS by buying a large lot (single heat number) of the filler wire
from an approved vendor from our Q ASL or in the past by buying a large lot (single
heat number) of wire and dedicating this wire by test.
The QVD contains the wire’s material traceability information for any and all the welding
performed on the project including weld wire used for the hole repair. Given this BNI
approved process is used to document welding performed in PVS’ shop, and given the
BNI approved hole filling procedure explicitly outlines the use of welding, it follows that
PVS has provided documentation in accordance with BNI approved procedures.

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.

PVS Understanding of the permission required by the engineer to use the Hole
Repair Procedure:
IPVS’ interpretation of the process for the restoration of the base metal needed because
of mislocated holes is dictated by the 2003 BNI approved hole repair procedure and the
BNI directive that all mislocated holes will be repaired is that no further hole by hole
approval is required. Neither the BNI approved procedure nor the BNI directive
requires PVS to submit a separate approval request each hole for approval.
This interpretation was additionally reinforced in the instructions for writing SDDRs
where it states, “The SDDR is not to be used for cases where RPP-WTP has previously
provided authorization to proceed using an accepted repair procedure covering a
specific type of repair; however, records must be maintained for each specific repair.”

PVS Current proposed change to the process used in the restoration of base
metal caused by mislocated holes:
Given the above information and PVS’s current understanding of BNI’s concerns, PVS
proposes the following change the process when a base metal repair is required
because of a mislocated hole.
1. When a mislocated hole is found the addressing NCR will not be closed until it
captures the welder, weld wire, and repair WPS on the NCR.
2. The PVS “Hole Repair” procedure will be revised to add the steps of creating the
PVS NCR and instruction to add information about the welder, weld wire, and
repair WPS.
3. A copy of the NCR will be added to the QVD package presented to the SQR for
approval to release the material / BOL.
For the reasons stated above there will not be an SDDR written each time a mislocated
hole has been identified nor will the NCR identify the location of the hole on the member
being repaired.

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