Page 1 \ 22 RCA Name Multiple leaks in new pipeline Report Number 2013-B105 Report Date 9/8/2013 RCA Owner Marcus McCoy Root Analysis Report Problem Statement Focal Point Multiple leaks in new HDPE pipeline When Start Date 6/3/2013 End Date 6/4/2013 Unique Timing Initial hydro testing of a new line during extremely hot weather Where Business Unit System Widget processing division Phoenix, AZ Process water treatment line Actual I mpact Revenue Customer Service Delayed startup-2 weeks $400,000.00 Repair of leaks and replacement of coupling gaskets $125,000.00 Customer upset due to delayed startup $0.00 Actual I mpact Total: $525,000.00 Frequency 1 times overall Potential I mpact Environmental Revenue Reportable spills $0.00 Lost future contracts $5,000,000.00 Clean up costs $100,000.00 Potential I mpact Total: $5,100,000.00 Report and chart generated by Sologic s link software. www.sologic.com
Report Summaries Page 2 \ 22 Executive Summary After over three miles of high-density polymer pipeline was installed with over 800 couplings, the initial 25 PSI hydro testing resulted in 50-60 percent of the couplings leaking. The couplings leaked because gaskets were damaged during installation and because the pipe sealing surfaces were improperly prepared. Gasket damage was caused by gasket misalignment because of improper lubrication being used to install the gaskets, among other problems. This problem resulted in a $525,000 profit reduction due to delaying startup by two weeks ($400,000) and increasing out-of-pocket costs by $125,000 for repairs. Our customer was also unhappy with the delays. Additional, potential impacts include reportable spills due to the leaks, possible loss of a $5M contract and $100,000 in clean up costs. include, but are not limited to, using a vegetable oil for gasket lubrication during installation; polishing the sealing areas of the pipe prior to installing gaskets; using a Sawzall with a fine tooth blade to cut pipe instead of a chainsaw; shading the installation surfaces on sunny, hot days; and incorporating the piping and coupling manufacturer's recommendations into the piping specifications. and Effect Summary The multiple piping leaks in the piping was caused by multiple leaks at the couplings. The couplings leaked because gaskets were pinched/damaged during installation and because the pipe sealing surfaces were improperly prepared. The pinched gaskets were caused by the gaskets not sliding into designated seating areas within the coupling. The gaskets did not slide adequately due to lack of lubrication which would have allowed the gaskets to seat properly when the coupling was tightened. The lubrication used during installation was a soapy water solution with an unknown ratio mix of water and soap. The ratio of soap and water is unknown because the installers did not track the amount of soap put in the water bottles, but it was stated that there was not much soap in the mixture. A soapy solution was recommended by the manufacturer, but considering this application in the hot, sunny desert climate, it was ineffective because the water evaporated too quickly. Aside from the gasket pinch, additional causes related to imperfections in the pipe surface area did not allow gaskets to form a seal. These imperfections include scratches, gouges, and abnormalities in the pipe s gasket surface area. Scratches were created mostly during pipe transfer from the storage/staging area to the installation area. The scratches came when the 50 foot pipe s ends dragged on the ground during transportation. The pipe is lifted from the center with a forklift, but the high-density polymer pipe is malleable (especially when heated from warm ambient temperature) and the flexibility of the pipe allows the ends to bend and touch the ground. While not in constant contact with the ground, the transportation path is not smooth, level, and flat so the ends come in contact with ground surface and rocks when moving into installation position. Most of the smaller imperfections were not addressed during the original installation (only the dramatic gouges were prepped or eliminated). The seemingly smaller surface area scratches and imperfections were not highlighted as an area of trouble during the onsite coupling training provided by the manufacturer, so installation technicians were not aware of which surface imperfections required attention and which imperfections were acceptable. The demonstration that the manufacturer's representatives provided during training included installation of a 3 coupling on 3 PVC pipe with no lubrication. Scratches, lubrication, and high-density polymer pipe were not addressed during this demonstration; however, it is noted that when asked if soapy water could provide sufficient lubrication for installation, the manufacturer's representatives confirmed that a soapy solution would be acceptable. It is important to note that the manufacturer was not part of this investigation, and evidence gathered is from the installer s statements, photos, and supporting documentation. The manufacturer did provide field installation
handbooks with additional installation instructions and recommendations, but these handbooks were not used during installation, as field personnel assumed the onsite training was sufficient enough to install the couplings. Other surface area imperfections were created from chainsaw cuts used to adjust the pipe length in between couplings. Occasionally, the 50-foot standard pipe length was not appropriate when navigating the plant area, so the pipe would have to be cut shorter for specific applications. These cuts are not factory cuts and thus introduce a surface area that may contain imperfections such as uneven cuts (out of square), chain marks on the end of the pipe, and excess material left from rough cuts. Lastly, the leaks were not detected until the pipeline construction was completed because no incremental hydro testing was performed during construction. Originally, the project manager assigned to this project had to leave shortly after bidding and project kick-off. Once construction began, a new highly-recommended project manager was assigned. While incremental pipe testing was discussed between the original project manager and the internal project engineer, the new project manager was not aware of the need and did not perform incremental testing. It is unknown why the new project manager did not perform in-construction hydro testing. The new project manager was unavailable for this investigation as he is no longer on this project. Page 3 \ 22
Page 4 \ 22 ID 1 Label Solution Description Use vegetable oil (or equiv) for gasket lubricant Soapy water used as gasket lubricant Ken Anderson Pass 9/9/2013 Status Completed Long $150.00 2 Solution Develop task package (better documention) Thought onsite training by manufacturer was sufficient This will help determine how to perform the task and what QC will need to be done with each task. 9/24/2013 Status Identified Long Pass 3 Solution Implement installation training that includes tightening torque. Include a certification and proficiency test. Improper tightening of coupling This solution will likely be addressed with the task package and formal training. This solution does not eliminate overtightening, but it does increase awareness. While the solution does not pass all criteria, it is considered a value added solution and should help reduce improper tightening of the coupling. Ken Anderson 9/15/2013 Status Identified Medium Pass 4 Solution Use Sawzall with fine tooth blade to cut pipe Chainsaw cuts aren't smooth Ken Anderson Pass 9/23/2013 Status Approved Short $400.00
5 Solution Design jig for moving pipe without pipe flexing (possibly using come-alongs and pipe ends) Pipe ends dragged on ground All pipe is already laid - this solution not necessary for this particular job - but could be useful for future. Further investigation is required to submit solution through criteria. Medium Status Not Checked Identified Page 5 \ 22 6 Solution Polish out scratches on pipe to ensure a smooth gasket surface before installation of gasket. HDPE pipe has surface scratches Cannot always eliminate scratching, but address scratches with surfacing process. This solution should be part of training and task package. Larry Davis 9/9/2013 Status Approved Short Pass 7 Solution Use file on scratches HDPE pipe has surface scratches Using a file is an alternative to using a flapper wheel when necessary. Alternative tool for smoothing out scratches and rough edges of pipe. Ken Anderson 9/9/2013 Status Identified Short Pass 8 Solution Use die grinder to smooth out scratches HDPE pipe has surface scratches Die grinder is an additional tool used to smooth out scratches and gasket surface imperfections. Ken Anderson 9/9/2013 Status Identified Short Pass 9 Solution Cut off section with scratch HDPE pipe has surface scratches
If gasket surface cannot be smoothed, it is recommended that the damaged area of the pipe be cut with a chainsaw and the new end prepped for gasket installation. Ken Anderson 9/29/2013 Status Identified Medium Pass Page 6 \ 22 11 Solution Develop and implement standard operating procedures (SOP) for installation. Excess material not removed Develop SOP. These procedures should be included in formal training. Formal training will allow for employee record tracking. Jim Jones 9/15/2013 Status Approved Long Pass 12 Solution New policy to enforce document read and signed-off. Incorprate into employee training records. Manufacturer's document not referenced by all installers Create new policy. Further investigation into how the policy will be communicated and governed is required to submit solution through criteria. Jim Jones 9/29/2013 Status Identified Long Not Checked 13 Solution Document training records on mechanical coupling installations. Manufacturer's document not referenced by all installers Implement formal training records to ensure that personnel working on pipe installation has been formally trained for task. John Smith 9/29/2013 Status Identified Choose Pass 14 Solution Incorporate manfuacturer's document into piping specs and issue with all jobs Manufacturer's installation document not used John Smith Pass
9/29/2013 Status Approved Medium Page 7 \ 22 15 Solution Fuse the pipes Leaks at mechanical joint (couplings) Not valid...customer wanted to use couplings to eliminate inside (ID) bead created from fusion. Ken Anderson Long Status Fail Identified 16 Solution Pipe caps during transportation HDPE pipe has surface scratches Implement a piece of equipment to protect the pipe ends from dragging on the ground. Further investigation required to determine feasibility of solution. 9/29/2013 Status Identified Medium Not Checked 17 Solution Work in evening or night shift hours Hot ambient temperature Solution may not be possible considering scheduling conflicts, but could be evaluated. Night time installation may increase unwanted safety and installation hazards. Investigate further. 9/29/2013 Status Identified Medium Not Checked 18 Solution Use water hose to cool HDPE pipe temperature Surface temperature of pipe was hot at install Solution may cause other unwanted obstacles with work area. Further investigation needed. 9/29/2013 Status Identified Short Not Checked
19 Solution Cover couplings until needed for installation Surface temperature of the coupling was hot at install Keep couplings covered to reduce direct sunlight that increases coupling surface temperature. Ken Anderson Pass 9/29/2013 Status Approved Short $300.00 Page 8 \ 22 20 Solution Include QA/QC in testing procedure. Separate installation and testing into two separate responsible parties. No incremental hydro testing performed on HDPE pipeline Control would assist in developing necessary testing procedures with installation team to incrementally test pipeline. John Smith 9/29/2013 Status Identified Long Pass 21 Solution Implement low pressure (air) and soap suds snoop test after every 1000' of line installed Hyrdo test is the only process to check for leaks Marcus McCoy Pass 9/26/2013 Status Approved Medium $50.00
Team Page 9 \ 22 ID Label Description Label Description 1 First Name John Last Name Smith Phone (1) Phone (2) Role District Manager Group Email john.smith@abc.com 2 First Name Jim Last Name Jones Phone (1) Phone (2) Role Email District Continuous Improvement Manager Group jim.jones@abc.com 3 First Name Larry Last Name Davis Phone (1) Phone (2) Role MPC - Project Engineer Group Email larry.davis@def.com 4 First Name Ken Last Name Anderson Phone (1) Phone (2) Role Hand Group Email ken.anderson@hij.com 7 First Name Rob Last Name Roy Phone (1) Phone (2) Role Project Manager Group Email rob.roy@abc.com 9 First Name Marcus Last Name McCoy Phone (1) 989-835-3402 Phone (2) Role Facilitator Group Artemis Email marcus.mccoy@artemisinvestigations.com
Page 10 \ 22 ID Label Description 1 Visual confirmation (pipe pressurized) Water in pipe 2 Pressure gauge Pipe pressurized Instrumentation 3 Couplings leaking Pipe pressurized Leaks at mechanical joint (couplings) Coupling gasket not properly aligned 4 Hyrdotesting procedure Water necessary for hydro testing
Page 11 \ 22 Direct Statement 5 Photos Surface imperfections on pipe Photo/Video 6 No other testing performed Coupling leaks not caught before final hydro test Original pipe superintendent did not do incremental testing on couplings Direct Statement 7 Past pipe experience expressed during recommendation Project personnel assumed that pipe super knew to incrementally test Direct Statement 8 Verbal witness statements (Hands) Employees not aware of HDPE pipe surface prepping needs Piping lifted from center wifth forklift
Page 12 \ 22 Direct Statement 17 Damaged gasket photos Coupling gaskets did not seal Coupling gaskets damaged Coupling gasket pinched Improper tightening of coupling Gasket area not adequately lubricated Soapy water not sufficient Photo/Video 18 Investigation gasket demonstration of creased gasket Coupling gaskets did not seal Gaskets rolled during installation Other... 19 Physical observation by technicians Coupling gaskets damaged Needed to change pipe length Gaskets are soft
Page 13 \ 22 20 Physical gouges in gasket Coupling gasket creased Gasket area not adequately lubricated Photo/Video 21 Clamp tightened Close clamp Soapy water not sufficient Soapy water used as gasket lubricant Mechanical coupling reps confirmed soapy water was sufficient Does not always provide complete coverage of gasket area Soapy water has thin consistency Hot ambient temperature Coupling in original shipping container (open top pallet) Soapy water evaporated before installation completed OD of HDPE pipe imperfect HDPE pipe has surface scratches Piping flexible HDPE pipe flexes when hot (heated from ambient weather) Pipe end dragged on rocks located in work area Onsite training by manufacturer did not enforce necessity of surface prepping Not mentioned by manufacturer reps Manufacturer reps did not illustrate prepping HDPE pipe Used 3" PVC pipe for demonstration Manufacturer reps did not apply lubrication to gasket/pipe during demo/training Not the same materials as being applied on site Manufacturer's installation document not used Thought onsite training by manufacturer was sufficient Manufacturer's document not referenced by all installers Factory cuts aren't perfect Chainsaw cuts aren't smooth Soapy water solution deemed acceptable
Gaskets got stuck on parts of pipe during installation Ease of sealing Fast Easy Soapy water loses is lubricity as water evaporates Soapy water (as lubricant) requires fast installation No incremental hydro testing performed on HDPE pipeline Field clean-up on pipe ends not performed Page 14 \ 22 Direct Statement 22 Mechanical coupling specs Coupling designed to not have extra material in gasket area Soapy water solution deemed acceptable Document 23 Newly installed gaskets not leaking Gasket area not adequately lubricated Ken Anderson 24 Spray bottles used during lubrication Soapy water used as gasket lubricant
Page 15 \ 22 Direct Statement 25 Physical observation of soapy lubricant Soapy water has thin consistency 26 Installer Observation Gravity causes soapy solution to drain to the bottom area of pipe OD of HDPE pipe imperfect Pipe end dragged on rocks located in work area Onsite training by manufacturer did not enforce necessity of surface prepping Manufacturer reps did not illustrate prepping HDPE pipe Not the same materials as being applied on site Installation requires gaskets to slide over pipe Couplings sitting out in the sun prior to install 27 Project Manager Statement Only viable option for application Piping flexible Forklift most viable option Use of forklifft more economical than crane Work area not favorable for crane 35% grade (crane not able to work on that grade) Hyrdo test is the only process to check for leaks Standard procedure for cutting pipe length
Surface temperature of the coupling was hot at install Page 16 \ 22 Direct Statement 28 Supervisor observation Arid ambient conditions Direct Statement 29 No documentation Original pipe superintendent did not do incremental testing on couplings 30 Manufacturer does not specify Document 31 Lack of records (no formal records or history)
Page 17 \ 22 32 Hot ambient temperature Couplings staged outside next to work area (about every 350 feet) Ease of installation Lower travel distance between couplings and pipe end Coupling in original shipping container (open top pallet) Soapy water evaporated before installation completed Pipe ends dragged on ground Need to transport pipe to final location HDPE pipe flexes when hot (heated from ambient weather) Forklift used to transfer HD pipe Work area not favorable for crane Manufacturer's installation document not used Thought manufacturer document was just for documentation purposes Pipe superintendent came highly recommended Hyrdo test is the only process to check for leaks Chainsaw cuts aren't smooth Needed to change pipe length Pipe ends sagged when pipe raised by forklift Soapy water solution convenient Surface temperature of pipe was hot at install Surface temperature of the coupling was hot at install Ends of the pipe contain imperfections Using chainsaw to make field cuts 33 Manufacturer field installation guide Soapy water would not chemically attack piping
Page 18 \ 22 Document 34 Project calendar Construction performed in summertime Document 35 Site located in mountains Construction site in desert 36 HDPE pipe photos HDPE pipe is black in color OD of HDPE pipe imperfect HDPE pipe has surface scratches Pipe ends dragged on ground Excess pipe material hung over and folded back onto pipe end Excess material not removed Factory cuts aren't perfect Photo/Video
Page 19 \ 22 37 HDPE pipe spec HDPE pipe is black in color HDPE pipe is heavy 38 In-house engineer statement Only viable option for application Larry Davis Direct Statement 39 Pipe location photos Photo/Video 40 Water pipeline currently exposed throughout site Direct Statement
Page 20 \ 22 41 Plant site temperature 90+ and surface temperature of pipe higher than 90+ Soapy water evaporated before installation completed 42? Not tightening each bolt evenly (together)? Not tightening in a cross pattern? Manufacturer reps not prepared? Choose 43? Overtightening one side? Choose 44 weather data Arid ambient conditions
Page 21 \ 22 Choose 45 scientific data/studies Black objects absorb maximum solar radiation Water evaporates quickly in desert Choose
s Page 22 \ 22 ID Label Description 1 No procedure for ratio used 2 Fusing pipes requires reaming - more time and less desirable Leaks at mechanical joint (couplings) 3 One person was originally scheduled to be superintendent and performed bidding and original scope. That first person had to leave jobsite and second person was assigned to be the new pipe superintendent. All pipe superintendent references are for the second person, not the first. Project personnel assumed that pipe super knew to incrementally test
Chart Legend Transitory Report and chart generated by Sologic s link software. Construction performed in summertime Non-transitory Omission - Transitory Omission - Non-transitory www.sologic.com g Hot ambient temperature Project calendar Focal Point f Solution Implemented Construction site in desert Work in evening or night shift hours Status Identified Solution may not be possible considering scheduling conflicts, but could be evaluated. Night time installation may increase unwanted safety and installation hazards. Investigate further. e Site located in mountains Arid ambient conditions Connects to: e Construction site in desert Supervisor observation weather data HDPE pipe is black in color Only viable option for application Soapy water evaporated before installation completed HDPE pipe photos HDPE pipe spec Project Manager Statement In-house engineer statement Plant site temperature 90+ and surface temperature of pipe higher than 90+ Surface temperature of pipe was hot at install Black objects absorb maximum solar radiation scientific data/studies Ease of installation Desired state Use water hose to cool HDPE pipe temperature Status Identified Solution may cause other unwanted obstacles with work area. Further investigation needed. Connects to: f Hot ambient temperature Couplings staged outside next to work area (about every 350 feet) Lower travel distance between couplings and pipe end Desired state Couplings sitting out in the sun prior to install Surface temperature of the coupling was hot at install Installer Observation Coupling in original shipping container (open top pallet) Project Manager Statement Connects to: g Hot ambient temperature Soapy water not sufficient Cover couplings until needed for installation Pass Status Approved Keep couplings covered to reduce direct sunlight that increases coupling surface temperature. Damaged gasket photos Soapy water has thin consistency Does not always provide complete coverage of gasket area Physical observation of soapy lubricant Gravity causes soapy solution to drain to the bottom area of pipe Installer Observation Gasket area not adequately lubricated Soapy water loses is lubricity as water evaporates Damaged gasket photos Physical gouges in gasket Newly installed gaskets not leaking Soapy water (as lubricant) requires fast installation Water evaporates quickly in desert Clamp tightened Close clamp Desired state scientific data/studies Mechanical coupling reps confirmed soapy water was sufficient? Gaskets rolled during installation Gaskets got stuck on parts of pipe during installation Soapy water solution deemed acceptable Investigation gasket demonstration of creased gasket Mechanical coupling specs Soapy water would not chemically attack piping Soapy water used as gasket lubricant Coupling gasket pinched Manufacturer field installation guide c Spray bottles used during lubrication Damaged gasket photos Use vegetable oil (or equiv) for gasket lubricant Soapy water solution convenient Pass Status Completed Installation requires gaskets to slide over pipe Installer Observation Coupling gasket not properly aligned Not tightening each bolt evenly (together)?? Water in pipe Water necessary for hydro testing Desired state Couplings leaking a? Visual confirmation (pipe pressurized) Hyrdotesting procedure Coupling gaskets damaged Improper tightening of coupling and or Overtightening one side?? Damaged gasket photos Physical observation by technicians Damaged gasket photos? Pipe pressurized Pressure gauge Couplings leaking Connects to: a Water necessary for hydro testing Implement installation training that includes tightening torque. Include a certification and proficiency test. Pass Status Identified This solution will likely be addressed with the task package and formal training. This solution does not eliminate overtightening, but it does increase awareness. While the solution does not pass all criteria, it is considered a value added solution and should help reduce improper tightening of the coupling. Not tightening in a cross pattern??? Coupling gaskets did not seal and or Coupling designed to not have extra material in gasket area Damaged gasket photos Investigation gasket demonstration of creased gasket Mechanical coupling specs Gaskets are soft Ease of sealing Desired state Physical observation by technicians Fast Desired state Coupling gasket creased Connects to: c Coupling gasket pinched Standard procedure for cutting pipe length Physical gouges in gasket Project Manager Statement Easy Desired state Using chainsaw to make field cuts Needed to change pipe length Desired state Leaks at mechanical joint (couplings) Physical observation by technicians Couplings leaking Fuse the pipes Fail Status Identified Not valid...customer wanted to use couplings to eliminate inside (ID) bead created from fusion. Ends of the pipe contain imperfections Chainsaw cuts aren't smooth Use Sawzall with fine tooth blade to cut pipe Pass Status Approved Factory cuts aren't perfect Need to transport pipe to final location Desired state HDPE pipe photos d Multiple leaks in new HDPE pipeline Pipe ends dragged on ground Piping flexible HDPE pipe flexes when hot (heated from ambient weather) HDPE pipe photos Pipe ends sagged when pipe raised by forklift Project Manager Statement Surface imperfections on pipe Design jig for moving pipe without pipe flexing (possibly using come-alongs and pipe ends) Status Identified All pipe is already laid - this solution not necessary for this particular job - but could be useful for future. Further investigation is required to submit solution through criteria. Piping lifted from center wifth forklift Photos HDPE pipe has surface scratches Verbal witness statements (Hands) HDPE pipe photos Pipe end dragged on rocks located in work area Connects to: d Need to transport pipe to final location Polish out scratches on pipe to ensure a smooth gasket surface before installation of gasket. Pass Status Approved Cannot always eliminate scratching, but address scratches with surfacing process. This solution should be part of training and task package. Installer Observation HDPE pipe is heavy Use file on scratches Pass Status Identified HDPE pipe spec Using a file is an alternative to using a flapper wheel when necessary. Alternative tool for smoothing out scratches and rough edges of pipe. Forklift used to transfer HD pipe Use of forklifft more economical than crane Desired state Use die grinder to smooth out scratches Pass Status Identified Die grinder is an additional tool used to smooth out scratches and gasket surface imperfections. Cut off section with scratch Forklift most viable option Project Manager Statement Pass Status Identified If gasket surface cannot be smoothed, it is recommended that the damaged area of the pipe be cut with a chainsaw and the new end prepped for gasket installation. Pipe caps during transportation Status Identified Project Manager Statement Work area not favorable for crane 35% grade (crane not able to work on that grade) OD of HDPE pipe imperfect Implement a piece of equipment to protect the pipe ends from dragging on the ground. Further investigation required to determine feasibility of solution. Project Manager Statement Project Manager Statement Installer Observation HDPE pipe photos Excess pipe material hung over and folded back onto pipe end Excess material not removed? Not mentioned by manufacturer reps Manufacturer reps not prepared? Not the same materials as being applied on site HDPE pipe photos HDPE pipe photos? Installer Observation Develop and implement standard operating procedures (SOP) for installation. Pass Status Approved Develop SOP. These procedures should be included in formal training. Formal training will allow for employee record tracking. Onsite training by manufacturer did not enforce necessity of surface prepping Used 3" PVC pipe for demonstration? Installer Observation Manufacturer reps did not illustrate prepping HDPE pipe Field clean-up on pipe ends not performed Employees not aware of HDPE pipe surface prepping needs Installer Observation Manufacturer reps did not apply lubrication to gasket/pipe during demo/training? Verbal witness statements (Hands) Thought onsite training by manufacturer was sufficient Original pipe superintendent did not do incremental testing on couplings? No incremental hydro testing performed on HDPE pipeline No other testing performed No documentation Manufacturer's installation document not used Develop task package (better documention) Pass Status Identified This will help determine how to perform the task and what QC will need to be done with each task. Coupling leaks not caught before final hydro test Include QA/QC in testing procedure. Separate installation and testing into two separate responsible parties. Pass Status Identified Control would assist in developing necessary testing procedures with installation team to incrementally test pipeline. Project personnel assumed that pipe super knew to incrementally test Past pipe experience expressed during recommendation Pipe superintendent came highly recommended Incorporate manfuacturer's document into piping specs and issue with all jobs Pass Status Approved Manufacturer's document not referenced by all installers Thought manufacturer document was just for documentation purposes? No other testing performed New policy to enforce document read and signed-off. Incorprate into employee training records. Hyrdo test is the only process to check for leaks Desired state Status Identified Create new policy. Further investigation into how the policy will be communicated and governed is required to submit solution through criteria. Document training records on mechanical coupling installations. Project Manager Statement Pass Status Identified Implement formal training records to ensure that personnel working on pipe installation has been formally trained for task. Implement low pressure (air) and soap suds snoop test after every 1000' of line installed Pass Status Approved