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DASHBOARD CERTIFICATION FACILITY DETAILS APPLICATIONS AUDITS

Facility ID: 17214

Audit ID: 82899

Initial 1st Surveillance - Primetech International Co.

Audit Dashboard
Finding Details
Findings

Finding Number Finding Status Review Decision Facility ID

1
10 Resolved Resolved 17214
10

11 Auditor Audit Type Finding Type Product/Service

UA Initial 1st Surveillance Minor Impact
12 Nonconformance Potential Impact
13

14

15

Requirement - MS Clause
16 Standard 5.2c
API Spec Q1 9th Ed
17

18 Description
In planning, the organization shall address legal and other applicable requirements.
19

20

Product Specification Clause

21 API-16A 7.4.6.9.1b)

22

Description
3 API 16C Clause 7.4.6.9.1 b)

4 Surface NDE requirements shall be as follows:

b) all magnetic particle examinations shall use the wet fluorescent method;
5

7 Objective Evidence
API 16C

8 Rigid Choke and Kill Lines

9
DD-16C-02-1

Rigid Choke Line 3 1/8” 5M R-35 (4ft Long) AISI 4130 Quenched and Tempered
Material DD Temp U H2S Service CRA Inlayed Ring Grooves

Files
Serial # 3315-1

QP-001-16C Rev 00 Dated 19th July 2020 Point 08 states NDT Applicable is MPI
whereas route card for the Flanges Reference Route Card # 3315-1 confirms that
LPI is carried out Point # 11 in the route card.

MPI identified and carried out is wet visible method whereas the applicable is
Fluorescent type MPI Clause 7.4.6.9.1

Nonconformance/Concern Description
The Route card which serves as a planning document of the process / activities is
not in line with the requirements of NDE identified in the Quality Plan.

Response

 Raneesh AK -  [16-Sep-2020]  [ Correction ]

Quality Plan # QP-001-16C was revised to define the specific NDE method as LPT and
also verified with the Route Card # 3315-1 and found all the identified processes are
identical in the Quality Plan and the Route Card.

Route cards issued for the prototype products was verified again to ensure that all
identified processes are identical with the respective quality plan and found there is no
discrepancy in the same.

The quality plan for all the products except API 16C Rigid choke and Kill line was found
to meet all the requirement.

The Quality Plan of Rigid and Kill Line was revised indicating the application of
fluorescent type MPI as required in clause 7.4.6.9.1 of API 16C, and the same is
applied in the NDE examination and found that the API 16C product do meet the
specified requirement.

After the API Audit, a proper Gap Assessment conducted considering all the API
specifications including all the errata and addendum were thoroughly verified.

 Raneesh AK -  [16-Sep-2020]  [ Root Cause Analysis ]

Quality Plan # QP-001-16C, Rev-00, dated on 14/01/2020 point 08 process description

state that “NDT inspection of rough machined ring grooves” and procedure reference
was PTI-WI-QC04 which is the procedure for LPT. During preparation of the route card,
LPT was defined in the route card, since the procedure PTI-WI-QC04 referenced in
quality plan and the inspection was also carried out as per route card. However,
evidential record section of Quality Plan wrongly mentioned as Magnetic Particle
Examination Report instead of Liquid Penetrant Examination Report.

While preparation of Quality Plan # QP-001-16C, Rev-00, dated on 14/01/2020 Weld

NDE - Surface examination was referred as MPI wet visible method instead of MPI wet
fluorescent, due to lack of information of requirements by the Quality Engineer.

 Raneesh AK -  [16-Sep-2020]  [ Corrective Action(s) ]

Quality plan procedure PTI-PR-QC01 revised on 05/08/2020 to detail the specific

mention of required inspection process shall be defined in the respective quality plans
as per the respective API product specification.

A training imparted to Quality Team and Workshop Supervisor on the revised control
features of Quality Plan Procedure PTI-PR-QC01 and the importance of specific
mention of inspection methods in the quality plan and in the route card. Effectiveness of
the training is verified by Quality Manager during the training by seeking answers from
the trainees on the trained topic and after the training by the review of revised and
updated Quality Plans and found that the training is effective.

All the resources for the MPI Wet Fluorescent method has been arranged internally
including Training for the QC Inspectors.

A new work instruction for the MPI Wet Fluorescent method has been developed in PTI
and the training and validation of the same has been carried out by our ASNT Level III.

General Manager imparted a training program to Operations Manager, Quality

Manager, Technical Manger and members of the Design Team in “Proper and thorough
verification of availability of all control features of respective API product specification in
all the Design Documentation” to ensure that all the Primetech Design Packages meet
all the criteria of API product specifications fully. The effectiveness of this training
program is verified by General Manager during the training session by seeking answers
 from the training participants on the trained topic and found that the training is effective.

 David Elliot -  [7-Oct-2020]  [ API Response ]

Your root cause requires deeper analysis. Why is does the record section of Quality
Plan wrongly mentioned as Magnetic Particle Examination Report instead of Liquid
Penetrant Examination Report? What gap in your QMS allowed the "Quality Engineers
to have a lack of information" and besides training what corrective action has been
implemented to prevent a recurrence of the gap identified in your root cause?

Has the facility shipped any products to customer claiming conformance to API 16A
(non-Monogramed) where the incorrect inspection was conducted? If so, what action
has been taken?

 Raneesh AK -  [7-Nov-2020]  [ Client Response ]

Primetech did not ship any API 16A or API 16C (Non monogrammed) product to any
customer so far. Only prototype product is produced for the requirement of API
License.

The mention of Magnetic Particle Inspection (MPI) for evaluation of Rough Ring Groove
machine instead of Liquid Penetrant Method is a typographical error.

However, the Route Card entry and actual evaluation method is by Liquid Penetrant
Method only as required by API specification.

The typographical error in the Quality Plan could have got detected if Design
Department representation also is ensured in the review process.

Now, the Quality Plan Procedure PTI-PR-QC01 is revised to include a review of all
Quality Plan by Asst. Manager (Eng.). All the Quality Plans are now subjected to a
cross check (Reviews) by Design and Planning department and the updated Quality
Plans are issued for implementation after ensuring that all the control features of
respective API specification are correctly stated in the Quality Plans.

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