ASME Section III Quality Manual I3 R1 03JA2011

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QUALITY MANUAL ASME CODE SECTION III

SANDVIK MATERIALS TECHNOLOGY PRODUCT AREA TUBE **** PRODUCT AREA WIRE AND HEATING TECHNOLOGY

Issue 3 Revision 1 JANUARY 3, 2011

UNCONTROLLED COPY

MAILING ADDRESS:

PLANT LOCATION:

SANDVIK MATERIALS TECHNOLOGY P.O. Box 1220 Scranton PA 18501-1220

982 Griffin Pond Road Clarks Summit PA 18411-9214

SANDVIK MATERIALS TECHNOLOGY P.O. Box 1220, Scranton, PA 18501-1220 Phone: (570) 585-7556

Q.A. Fax: (570) 585-7540

SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

INTRODUCTION AND GENERAL

Section: 0.1 Issue: 3 Revision: 1 Date: 01/03/2011

Table of Contents

Section

Title Cover Page

0

Of: 3

Rev. No.

Rev. Date

1

01/03/2011

1 1 1 0

01/03/2011 01/03/2011 01/03/2011 04/08/2009

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04/08/2009 04/08/2009 04/08/2009 04/08/2009

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01/03/2011 01/03/2011 04/08/2009

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04/08/2009 04/08/2009

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04/08/2009 04/08/2009 01/03/2011 04/08/2009 04/08/2009

INTRODUCTION AND GENERAL 0.1 0.2 0.3 0.4

1

Table of Contents Glossary Introduction Procurement and Supply of Tubular and Welding Products per ASME Code Section III from Other Material Organizations

RESPONSIBILITY AND ORGANIZATION 1.1.1 1.1.2 1.2 1.3.1

General General - Planning and Contact Review Scope and Applicability Organization – Quality Policy and Management Statement of Authority 1.3.2 Organization – Responsibility and Authority 1.3.3 Organization – Organizational Charts 1.3.4 Organization – Management Review

2

PERSONNEL 2.1 2.2

3

Indoctrination, Training and Qualification of Personnel Personnel Records

PROGRAM DOCUMENTATION 3.1 3.2 3.3 3.4 3.5

4

Page: 1

Quality Manual Procedures, Instructions, and Drawings Document Control Quality Assurance Records Records of Examinations and Tests Intentionally Skipped

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

INTRODUCTION AND GENERAL

Section: 0.1 Issue: 3 Revision: 1 Date: 01/03/2011

Table of Contents

Section

Title

5

Page: 2

Of: 3

Rev. No.

Rev. Date

CONTROL OF PURCHASED MATERIALS, SOURCE MATERIALS, AND SERVICES 5.1 5.2

0 1

04/08/2009 01/03/2011

5.3

General Sources of Materials, Source Material, and Services including the Approval and Control of Suppliers of Source Material and Service Intentionally Skipped

5.4 5.5 5.6 5.7

Procurement Document Control Utilization of Unqualified Source Material Verification of Purchased Material, Products and Services Direct Shipment of Material from a Material Organization

0 0 0 1

Intentionally Skipped 04/08/2009 04/08/2009 04/08/2009 01/03/2011

0 0

04/08/2009 04/08/2009

0

04/08/2009

0

Not Applicable

0 0 0 0 0

04/08/2009 04/08/2009 04/08/2009 04/08/2009 Not Applicable 04/08/2009

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04/08/2009 04/08/2009 04/08/2009 04/08/2009 04/08/2009 04/08/2009 04/08/2009

6

INDENTIFICATION, MARKING, AND MATERIAL CONTROL 6.1 General 6.2.1 Marking Method and Indentification of Completed Material Tube 6.2.2 Marking Method and Indentification of Completed Material Wire 6.4 Welding and Brazing Materials Identification

PROCESS CONTROL

7 7.1.1 7.1.2 7.1.3 7.2 7.3 7.4

8

General Special Processes Maintenance of Equipment Manufacturing Process Control Welding Handling, Storage, Shipping, and Preservation

CONTROL OF EXAMINATIONS, TESTS, AND NONCONFORMING MATERIAL 8.1.1 8.1.2 8.1.3 8.2 8.3 8.4 8.5

Inspection, Examination, and Test Control - Inspection Inspection, Examination, and Test Control - Testing Inspection, Examination, and Test Control – Records Control of Measuring and Test Equipment Discrepancies in Measuring and Test Equipment Inspection and Test Status Control of Nonconforming Material

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY Section: 0.1 Issue: 3 Revision: 1 Date: 01/03/2011

INTRODUCTION AND GENERAL Table of Contents

Section

Title

9

Page: 3

Of: 3

Rev. No.

Rev. Date

AUDITS AND CORRECTIVE ACTION 9.1 9.2

Audits Corrective Action

10

CERTIFICATION REQUIREMENTS

11

FORMS AND DOCUMENTS 11.1

1 0

List of Forms and Documents

01/03/2011 04/08/2009 0

04/08/2009

0

04/08/2009

Manual Revision Approval:

Keith M. Hottle Director, Quality and Metallurgy

01/03/2011 Date

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

Introduction and General

Section: 0.2 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 1

Of: 12

Glossary

Accepted Order

Agreed requirements between Sandvik Materials Technology and customer transmitted by any means.

5

Approval

An act of endorsing or adding positive authorization or both, indicated by stamp, initial, or employee identification number and a date of the approval.

Approved Supplier

A supplier that has been evaluated and approved by Sandvik Materials Technology in accordance with requirements of ASME Code Section III NCA-3800 to supply qualified source material for conversion to material, or

10

provision of services, to Sandvik Materials Technology.

Audit

A documented evaluation performed to verify, by examination of objective evidence, that those selected elements of a previously approved quality

15

program have been developed, documented, and implemented in accordance with specified requirements. An audit does not include surveillance or inspection for the purpose of process control, or acceptance of material or items.

20

Certification

The act of verifying and attesting in writing that documents, processes, procedures, source material, material, products, or the qualification of personnel are in accordance with specified requirements.

Certified Material 25

Code material which is in accordance with Certified Material Test Report (CMTR) specified requirements, including the actual results of all required chemical analyses, tests, and examinations. For non-Code material and products, see Certification.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

Introduction and General

Section: 0.2 Issue: 3 Revision: 1

Date: 01/03/2011

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Of: 12

Glossary

Certified Material

A document attesting that the material is accordance with specification

Test Report (CMTR)

requirements, including the actual results of all required chemical analyses, tests, and examinations.

Contamination 5

Foreign materials such as mill scale, dirt, oil, chemicals; any matter that renders a fluid, solid or surface impure and unclean according to preset standards of acceptable cleanness.

10

Contract

See Accepted Order.

Continuous

Actions taken continuously throughout the organization to increase the

Quality

effectiveness and efficiency of activities and processes to provide added

Improvement

benefits to both the organization and its customer.

Code

American Society of Mechanical Engineers Boiler and Pressure Vessel Code

Control Procedure

Instructions and Procedures issued and controlled by Quality Assurance.

and Instruction

Commonly referred to as "CPI's", these instructions and procedures shall be

15

approved by Quality Assurance. These CPI's are sometimes referred to as "Quality Assurance Procedures" and "detailed specifications written 20

instructions and procedures".

Corrective Action

Measures taken to rectify conditions adverse to quality, and, when necessary, to preclude repetition.

25

Customer

The organization doing the buying from Sandvik Materials Technology.

Customer Order

The document issued by a customer for buying products from Sandvik Materials Technology.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

Introduction and General

Section: 0.2 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 3

Of: 12

Glossary

Defective Material

Material that does not meet specified requirements.

Designee

Any person that performs a specific activity at the request of the person

5

primarily responsible for the activity. The person designating the activity retains primary responsibility for the activity performed by the designee.

10

Discrepancy

A condition outside of an established tolerance or requirement.

Documentation

Any written or pictorial information describing, defining, specifying, reporting or certifying activities, requirements, procedures or results.

Document Control

Those measure established to control the preparation, review, release, issuance, and disposition of documents, such as purchase orders,

15

specifications, instructions, procedures, and drawings, including changes thereto, that describe or document activities affecting quality.

Examination

Specific actions by qualified personnel using qualified procedures to verify that source material and material are in accordance with specified

20

requirements. This term, when used in conjunction with qualification of personnel to perform quality related activities, shall mean written examination.

25

Executive

Sandvik Materials Technology - NAFTA President and staff which

Management

includes the managers of the four operating product areas/sales units and support services. (Company Top Management)

Final Inspection

Inspection which is performed on finished product before release for shipping or stocking. For Code requirements it is performed by Quality Assurance.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

Introduction and General

Section: 0.2 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 4

Of: 12

Glossary

Heat of Material

Material produced from the same melt of metal.

(Heat Number)

5

Hydrostatic Test

The pressurization of material to a test pressure using water or other liquid as a testing medium with required examination per the Code

In-Process Inspection

Inspection which is performed during the manufacturing in an effort to detect defects prior to further processing.

10 Incoming

Inspection which is performed on source material and material prior to or

Inspection

after being assigned to a work order before start of manufacturing. For Code requirements it is performed by Quality Assurance.

15

Inspection

The actual act of verifying the conformance of source material and material to specified requirements for the purpose of acceptance or rejection.

Inspector

A qualified employee of an organization whose duties include verification of quality-related activities such as inspection, test and/or examination.

20

Item Master

List of source material and/or material used to manufacture finished product.

Lot of Covered

The quantity of electrodes produced from the same combination of heat of

Electrodes

material and dry batch or dry blend of covering mixture. Where applicable,

(Lot Number)

military lot definitions shall apply.

Material

Metallic materials manufactured to an SA, SB, SFA, or any other material

25

specification permitted in Section III of the Code, and that are manufactured, identified and certified in accordance with the requirements of Section III of the Code. G:\Quality Assurance\Controlled Documents\ASME Manual\Issue 3 Revision 1\0-2 Issue 3 Rev 1.DOC

SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

Introduction and General

Section: 0.2 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 5

Of: 12

Glossary

Material

See “Certified Material Test Report” and Certification.

Certificate

5

Material

An organization certified by holding Quality System Certificate issued by

Organization (Metallic) ASME to provide materials or services in accordance with the

10

Accredited

requirements of ASME Code Section III, NCA-3800.

Material

An organization surveyed and qualified by to provide materials and services

Organization (Metallic) in accordance with the requirements of ASME Code Section III, NCA-3800 Qualified

to the accredited Material Organization (Sandvik Materials Technology) that performed the qualification.

Material Specification

A document that establishes the requirements of material.

Nonconformance

A deficiency in characteristic, documentation, or procedure which renders an

15

item unacceptable or indeterminate. Examples on nonconformance include: physical defects, test failures, incorrect or inadequate documentation, or deviations from prescribed processing, inspection or test procedures. 20 Nondestructive

The use of inspection methods intended to detect surface and internal

Examination (NDE)

discontinuities in material that do not affect or change the items being

and Nondestructive

evaluated. Nondestructive testing methods are those which do not affect or

Testing (NDT)

change an item, such as radiographic, ultrasonic, liquid penetrant, magnetic

25

particle, eddy current and visual examination and leak testing.

Operating Directives

Documented work instructions prepared by Production and approved,

and Instructions

issued and controlled by Quality Assurance.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

Introduction and General

Section: 0.2 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 6

Of: 12

Glossary

Order

5

Acknowledgment

See Sales Order.

Package

A wrapping or container including its content of material.

Performance

A documented evaluation of material supplied by a previously

Assessment

audited and accepted Quality System Program to verify continued compliance with Code requirements. Performance assessments shall

10

document the effectiveness of the qualified material organization’s quality system program and meet the following requirements: (1) Assessment frequencies shall be commensurate with the schedule of production and procurement, but shall be conducted at least once annually during the interval in which material or source material are controlled, (2) Assessments

15

shall include a documented review of the qualified material organization’s history of conditions adverse to quality, nonconformances, and corrective actions, and (3) Assessments shall include a documented review of periodic testing performed since the last assessment to demonstrate conformance of sample materials to selected requirements of the material specification.

20

Such testing shall be conducted during the period since the last assessment by the party performing the evaluation.

Procedure

A document that specifies or describes how an activity is to be performed. It may include methods to be employed, equipment or materials to be used

25

and sequence of operation.

Process Control

A planning tool used to summarize and document for key product and key

Plan

control characteristics, the capability of process/measuring system and the plan to control the process.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

Introduction and General

Section: 0.2 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 7

Of: 12

Glossary

Process Outline

The sequential process steps to be taken for manufacture, testing, examination, and inspection of final product or material.

5

Procurement

Contractually binding documents that identify and define the requirements

Documents

which materials or services must meet in order to be considered acceptable by the purchaser.

Product Area

Term used synomously with division.

Product Area Quality

Individual assigned to the product area to maintain the operational controls

Professional

of the quality assurance program. Titles may include Quality Manager,

10

Manager – Quality Assurance, Quality Engineer, Sr. Quality Assurance Specialist, or Quality Assurance Specialist. 15

20

Product Area

Product Area General Manager and staff which includes the managers

Management Team

of the major functional areas within each product area.

Product Area Wire

Synonomous in this program with Product Area Wire or Welding and Wire

and Heating

Division.

Technology

25

Product Requirement

That document prepared by Quality Assurance which is used in interpreting

Review Sheet (PRR)

and specifying in detail the requirements of a specification or customer order. Also referred to as "Specification and Order Review", "Specifications Review", "Spec Review" and "Technical Requirement Review" in some Quality Assurance documents and records.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

Introduction and General

Section: 0.2 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 8

Of: 12

Glossary

Purchase Order

The document issued by Sandvik Materials Technology for procurement of materials, products and services.

Qualified Source 5

Metallic products produced by an approved supplier, Material Organization, or

Material

Certificate Holder in accordance with the requirements of NCA-3800 or the output requirements of the qualification process requirements of NCA3855.5.

10

Quality Assurance

All those planned or systematic actions necessary to provide adequate confidence that all materials and products designed, manufactured and supplied are in accordance with the applicable rules of ASME Code Section III, 10CFR50 Appendix B, and customer order requirements.

15

Quality Manual

A written document that describes the Quality Assurance Program.

Quality System

A controlled system of planned and systemic actions required to provide

Program

adquate confidence that materials conform to the requirements of the rules of Section III.

20

Quality Control

Measurement of the characteristics of material, products or process to determine conformance to specified requirements.

25

Quality Control Plan

See Process Control Plan

Quality Function

The function within Sandvik Materials Technology having the overall responsibility for the Quality System. This function includes the Quality Assurance Department, Scranton Works,the Materials Laboratory, and inspection and testing.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

Introduction and General

Section: 0.2 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 9

Of: 12

Glossary

5

Quality Improvement

A permanent cross-functional team formed in each product area to

Team (QIT)

manage the Continuous Quality Improvement process.

Quality Plan

See Process Control Plan

Quality System

A Certificate issused by ASME that permits an organization to perform

Certificate (QSC)

specified Material Manufacturer or Material Supplier activities in accordance with Code requirrements.

10 Quality System

A Material Organization that maintains an ASME Quality System Certificate

Certificate Holder

in accordance with the requirements of NCA-3800.

(Metallic)

15

Quality System

A documented system of actions required to provide adequate confidence

Program

that materials conform to the requirements of the Material Specification and the rules of ASME Code Section III.

20

Receiving

An act performed on source material and material prior to being assigned

Verification

to a work order and on finished goods from outside suppliers to verify to the purchase order type of material, quantity, size, marking, labeling and condition of the shipment.

Repair (Rework) 25

The process of physically restoring a nonconformance to a condition such that the material complies with Code requirements.

Review

An act of looking over or studying a document. A review, resulting in acceptance, shall be indicated by stamp, employee identification number, initial or signature and date.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

Introduction and General

Section: 0.2 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 10

Of: 12

Glossary

Sales Order

Those document sets issued by the Sales Department of Sandvik Materials Technology used to process a customer order. The Sales Order sets include the Order Acknowledgment set and the Shipping Order set. the Sales Order

5

is sometimes referred to as the Order Acknowledgment in documents and records.

10

Sandvik AB and

Parent companies of Sandvik Materials Technology, located in Sandviken

AB Sandvik Materials

Sweden.

Technology

Sandvik Materials

The official name of this company. Sometimes referred to in this Manual as

Technology

Sandvik. Certain quality documents may still refer to Sandvik Steel Company.

15 Shop Order

See “Work Order”

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

Introduction and General

Section: 0.2 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 11

Of: 12

Glossary

Source Material

Metallic products used by a Material Organization or Certificate Holder in a product form conversion process in the manufacture of material [NCA-3851.2 (a) (1)] or in the qualification process based on test and examination to the

5

requirements of the material specification [NCA-3855.5 (a) (2) and (3)]. Source material may be qualified or unqualified.

Special Process

A process, the results of which are highly dependent on the control of the process or skill of the operator, or both.

10 Specification

A concise statement of a set of requirements to be satisfied by a product, a material or process indicating whenever appropriate, the procedure for determining whether the requirements given are satisfied.

Supplier 15

Any individual or organization that furnishes materials or services in accordance with a procurement document.

Survey

A documented evaluation of an organization's ability to perform Code activities as verified by a determination of the adequacy of the organization's quality program and by a review of the implementation of the program at the

20

location of the work.

Tender

Offer made by Sandvik Materials Technology in response to an invitation to satisfy a contract award to provide product.

25

Testing

An element of verification for the determination of the capability of materials or products to meet specified requirements by subjecting the materials or products to a set of physical, mechanical, chemical, environmental or operating conditions.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

Introduction and General

Section: 0.2 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 12

Of: 12

Glossary

Traceability

The ability to verify the history , location, or application of material by means of recorded identification.

Traveler

See “Work Order”

Tubular Products

Synonomous in this program with Product Area Tube.

5

Division

10

Unqualified Source

Source material not produced by a Material Organization or approved

Material

supplier in accordance with the requirements of ASME Code Section III NCA-3800.

15

Vendor

See Supplier

Verification

A review to ensure that activities have been performed and documented in accordance with applicable requirements.

Wire Products

Wire for non-welding applications, such as spring wire and wire for medical devices. Material for Wire Products may meet the Code, but the product as

20

25

defined above is not included in ASME Code Section III.

Work Instruction

See Operating Directives and Instructions

Work Order

That document or document set used by Production which outlines the sequence of operations used in manufacturing. The Work Order is sometimes referred to as "Traveler", "Shop Order", and "Mill Order".

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

INTRODUCTION AND GENERAL

Section: 0.3 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 1

Of: 1

Introduction

The purpose of this Quality Manual is to describe and summarize the Quality System Program requirements per ASME Code Section III, nuclear safety-related requirements and certain MIL applications and requirements for manufacturing and supplying of products from the Product Area Tube and Product Area Wire. 5 The Quality System Program is designed to specifically meet the ASME Code Section III NCA3800.

The Quality System Program is also intended to meet the requirements of 10CFR50, Appendix B, 10

10CFR Part 21, and ASME NQA-1, 1989 Edition and 1994 Edition, 1995 Addenda, Basic Requirements.

A separate quality manual exists to identify requirements per ISO 9001/ANSI Q9001 for tubular products, welding and wire products, as well as products from the Spring Products Division and 15

Product Area Strip.

This Issue 3, Revision 1 of the Manual addresses editorial corrections to address title inconsistencies, organizational changes in Product Area Tube, Product Area Wire and Heat Technology, and Quality and Metallurgy and to remove the requirement that suppliers of 20

subcontracted auditing services must be evaluated using Appendix 2A-3 of ANSI/ASME NQA-1, 1994 Edition, 1995 Addenda.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

INTRODUCTION AND GENERAL Procurement and Supply of Tubular and Welding Products per ASME Code Section III from Other Material Organizations

Section: 0.4 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 1

Of: 3

As a Material Organization, Sandvik Materials Technology supplies material purchased from accredited or qualified Material Organizations in accordance with the ASME Code Section III. Products purchased and supplied are ferrous and nonferrous bars, seamless and welded without filler metal tubular products, bare and covered electrodes, bare wire, strip electrodes, welding flux, 5

powdered filler metal, tube hollows, hot rolled rod and wire, and complementary products such as plate, flanges, fittings, and forgings.

Qualification and approval of Material Organizations from which material is procured is given by the Director/Manager, Quality and Metallurgy, per Section 5, "Control of Purchased Materials, Source 10

Materials, and Services", of this Manual.

Procurement of material from these approved Material Organizations, listed on the Approved Suppliers List for ASME Section III and Military Applications, is controlled by the use of Sandvik internal specifications and additional procurement information as applicable, stated on the purchase 15

order, which is reviewed and approved by the Product Area Quality Professional when specified in Section 5, "Control of Purchased Materials, Source Materials, and Services", of this Manual.

Control of purchased material is accomplished by a receiving verification per Section 5, "Control of Purchased Materials, Source Materials, and Services", of this Manual. Before any material is placed 20

in inventory, the Product Area Quality Professional (or designee) verifies all receiving verification steps to assure that received material meets the requirements per the purchase order.

Verification is documented by Product Area Quality Professional (or designee) by reviewing and approving the Certified Materials Test Report or Certification. Approval is indicated by stamping, 25

signing, and dating the Certified Material Test Report or Certification. In addition, the material is released by Quality Assurance in the computer system via the assignment of a nuclear quality symbol for the relevant heat number and lot number.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

INTRODUCTION AND GENERAL Procurement and Supply of Tubular and Welding Products per ASME Code Section III from Other Material Organizations

Section: 0.4 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 2

Of: 3

Materials kept in inventory shall be identified and traceable to the procurement documents by heat/lot number and purchase order number.

When a need exists to transfer identification marking of

material during re-line marking of pipe and tube after cleaning, and re-label and re-packaging of welding material, controls are established by performing the identification marking transfer under a 5

work order. See Section 7, "Process Control" and Section 6, "Identification, Marking, and Material Control" of this Manual. The transferred identification marking shall, as a minimum, contain the same information as prior to the transfer.

Customer orders are reviewed by Inside Sales and Quality Assurance. Sales will issue the Sales 10

Order (EXHIBIT 1) indicating the relevant Product Requirement Review Sheet (EXHIBITS 2 and 3), previously approved by the Product Area Quality Professional per Section 3, "Contract Review", of this Manual. The Product Requirements Review Sheet (EXHIBITS 2 and 3) summarize the customer requirements. Reference to the Product Requirement Review Sheet shall be made by Inside Sales on the Sales Order.

15 Application of material to the customer order as specified on the Sales Order, by Inside Sales, is done by Inventory Control.

Additional material testing and nondestructive examination required per the customer order are 20

indicated by the Product Area Quality Professional on the Product Requirement Review Sheet. Controls of these activities are maintained by the Product Area Quality Professional per Section 8, "Control of Examinations, Tests, and Nonconforming Material" of this Manual.

Unqualified source material applied to a customer order shall be purchased, tested and controlled 25

under the provisions of Section 5.5, "Utilization of Unqualified Source Material", of this Manual.

Prior to shipping, the identification marking of tube and pipe and welding material is verified by warehouse personnel. For tube and pipe, this is documented through an electronic transaction in the

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mainframe computer system. For welding material, the packing note is signed and dated by the warehouse personnel.

The Product Area Quality Professional (or designee) reviews the sales/shipping order, the Material 5

Organization's Certified Material Test Report, or the Supplier’s certification, as applicable,

work

orders, and other test and examination records as applicable. Approval of records is indicated by the Product Area Quality Professional/Designee's signature and date on the Sandvik certification of materials as indicated below.

10

When the reviews per above by the Product Area Quality Professional show that the requirements per the customer order have been met, a Sandvik Material Certificate is prepared and signed by the Director/Manager, Quality and Metallurgy, or appointee, in accordance with Section 10, "Certification Requirements" of this Manual.

15

All applicable certifications received from other Material Organizations or Suppliers shall be transmitted to the customer together with the Sandvik Material Certificate at time of shipment.

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General

The purpose of this Quality Manual is to describe and summarize the Quality System Program requirements per ASME Code Section III, nuclear safety-related requirements, and certain MIL applications and requirements for manufacturing and supplying of products from the Product Area Tube and Product Area Wire. 5 The Quality System Program Program is intended to assure the quality during all phases of the manufacturing and supply activities for Product Area Tube and Product Area Wire. The Quality System Program Program is planned, documented, implemented and maintained to specifically meet the requirements of ASME Code Section III NCA-3800. 10 The Quality System Program Program, as documented, addresses the technical aspects and provides for the planning and accomplishment of those activities affecting quality. The Quality System Program Program, as documented, provides for the control of special processes, processes, inspection and test equipment, tools, and the requisite skills to ensure that the 15

required quality is attained and verified.

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In order to assure that quality requirements are met, to suit Sandvik’s method of operation, and to be consistent with all other requirements of the Quality System Program, the format used for Quality Planning is process outlines (shop travelers, product requirement reviews, etc.).

5

The process outline is a documented listing of all manufacturing, testing, examination, inspection and other control steps, such as customer hold points. Applicable Control Procedures and Instructions (CPI’s) are indicated by procedure number on the Process Outline.

Specific Process Control Plans/Quality Control Plans (EXHIBIT 18) are prepared, revised, issued and 10

controlled by Quality Assurance when required by customer orders or when deemed meaningful and appropriate by Quality Assurance.

Written procedures in the form of Control Procedures and Instructions (CPI’s) are established and maintained for contract review and for the coordination of these activities. 15 The Sales Department in each Product Area is responsible for receipt of all requests for quotations and all customer orders and contracts. The responsible salesperson will identify and review all customer requirements associated with the request for quotation or the order. This initial review is conducted for the purpose of confirming that all requirements can be met. 20

Order changes or

amendments are subject to the same review process as a new order.

Before submission of a quotation (tender) or at the acceptance of an order, any unclear or incomplete requirements shall be resolved with the customer as soon as possible to prevent errors or delays in completing the order. If the sales person has concerns about manufacturing capabilities, Production 25

Management and/or Process Engineering is to be contacted and capabilities confirmed. Concerns with regard to inspection and testing requirements shall be resolved with the Quality Assurance Department.

The Traffic Department or , in the case of tubular products, the North American

Distribution Center are to be contacted should there be questions about handling and shipping

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requirements.

Of: 4

Any exceptions to or deviations from stated written requirements shall be

communicated in writing to the customer.

Verbal orders are not acceptable for Code work. 5 The sales person is responsible for determining if the customer order conforms to one or more of the following conditions which require additional review by the Quality Assurance Department per applicable Control Procedure Instruction (CPI): 10

1. Orders for nuclear material to be manufactured to ASME Section III requirements, where class, edition and addenda are specified.

2. Orders having additions to, or invoking specific provisions of the ASME Code Section III.

15

3. Orders intended to fulfill any government contract shipping directly to a government facility from Sandvik Scranton.

4. Orders requiring source inspection of any kind to be performed at Sandvik Scranton.

20

5. Orders having unique requirements or product specifications written by the customer or end user.

6. Orders requiring additions or exceptions to, or deviations from, established product specifications or standards, and/or internal procedures.

25

If the order meets any of the conditions defined above, copies of the customer purchase order, government contract (as applicable), and all supporting documentation are submitted to the Quality Assurance Department for further review before continuing.

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Documents reviewed or approved by the Product Area Quality Professionals are customer orders, sales orders and work orders. For orders with high integrity requirements, such as ASME Code Section III,

a customer order and specification review is performed by Product Area Quality

Professionals, and a Product Requirement Review Sheet is issued by the Product Area Quality 5

Professionals (EXHIBITS 2 and 3), which will specify what requirements must be fulfilled for the effective and correct processing of the customer order. When Control Procedures and Instructions are referenced on a Product Requirement Review Sheet, no revision level for Control Procedures and Instructions is required. All operations shall be completed to the latest revision of the referenced Control Procedures and Instructions as controlled in Section 3.3 of this manual. Personnel in Sales,

10

Production, and Quality Assurance are responsible for the execution of the details documented on the Product Requirement Review Sheet. A hard copy or electronic copy of the Product Requirements Review Sheet is made available to Sales and Production.

Quality Function personnel review, prior to shipping, in conjunction with the certification of the 15

material the Sales Order, (EXHIBIT 1) which is issued by Sales to Production to cover the application of material either inventoried or manufactured by Sandvik to a Customer Order. This Order specifies type of product, grade, size, quantity, customer name and, when available, heat number and/or lot number. Special order requirements which have been documented on the Product Requirement Review Sheet which Quality Assurance has performed on the original customer order are also

20

indicated or referenced on the sales order.

If a customer requires special instructions or procedures, they shall be documented in a Control Procedure and Instruction or a Product Requirement Review Sheet issued by the Quality Assurance Department. 25

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If a customer change notice or amendment is received during the processing of an order, previously reviewed and approved by Quality Assurance, the change notice or amendment is sent to the Product Area Quality Professional for review and approval.

If necessary, the original Product

Requirement Review Sheet will be revised to show any changed or additional requirements that must 5

be fulfilled for the effective and correct processing of the change order. The Product Area Quality Professional will immediately hand carry copies of or electronically distribute the revised specification review to the foreman, production control and inspector in the plant where the material is being processed. The Product Area Quality Professional or Production Control will show the latest Product Requirement Review Sheet revision number on all travelers and test reports, and sign and date the

10

changes. The Product Area Quality Professional will review all manufacturing steps completed to insure that the steps do not violate the requirements of the change order. If found acceptable, the Product Area Quality Professional or designee will sign and date the traveler. If not acceptable, the Product Area Quality Professional will issue a Non-Conforming Material Report (EXHIBIT 17) and reject tag (EXHIBIT 5) in accordance with Section 8.5, "Control of Nonconforming Material" of this

15

Manual.

All contract review records shall be maintained per Section 3.4, “Quality Assurance Records”, per this Manual.

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Scope and Applicability

General The manufacturing programs and products stored, supplied and shipped by Sandvik Materials Technology per Code requirements are handled by two product areas, namely Product Area Tube and Product Area Wire. 5 The scope of activities include the following: −

The shipment of material from qualified Material Organizations to parties other Sandvik Materials Technology.

10



The qualification of non-accredited Material Organizations.



The utilization of unqualified source material.



The approval and control of suppliers.

Product Area Tube The tubular products operations at Sandvik Materials Technology include manufacturing, 15

warehousing, and shipping of ferrous and nonferrous seamless pipe and tubes. Per ASME Code Section III, this is done as a Material Organization in accordance with the requirements of ASME Code Section III, NCA-3800.

The manufacturing processes used for seamless pipe and tubes are reduction by pilgering of 20

tube hollows received either from AB Sandvik Materials Technology, Sandviken, Sweden or from other approved suppliers of source material.

Examples of other processes applied during

manufacturing are degreasing, cleaning, annealing, straightening, belt polishing, cutting, testing, inspection, examination, marking, and packaging.

25

The operations also include activities as a material supplier for procurement, receiving verification, warehousing, testing, examination, inspection, and shipping of ferrous and nonferrous bars, tube hollows, and pipe and tube, seamless and welded without filler metals. Per

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Scope and Applicability

ASME Code Section III, this is done as a Material Organization by furnishing material purchased from Material Organizations or source material purchased from Approved Suppliers under provisions necessary to assure compliance with the ASME Code Section III. See Section 0.4, “Procurement and Supply of Tubular and Welding Products per ASME Code Section III from 5

Other Material Organizations” of this Manual.

No weld repair will be performed even when

permitted by the applicable material specification(s).

Tubular products manufactured and supplied by Sandvik Materials Technology are processed, tested, and inspected in accordance with the requirements of applicable ASME Codes and ASTM 10

specifications, or other required standards or customer specifications.

Product Area Wire The manufacturing, warehousing and shipping of welding materials at Sandvik Materials Technology include various sizes of bare welding wire, electrodes and rods, and covered welding 15

electrodes for ferrous and nonferrous materials. Per ASME Code Section III requirements, this is done as a Material Organization in accordance with the requirements of ASME Code Section III, NCA-3800.

The bare welding wire and rod operations include but are not limited to hot rod preparation, 20

drawing, annealing, spooling, coiling, cutting, straightening, polishing, cleaning, labeling, packaging, alloy identity testing, inspection and final acceptance testing.

As a material supplier, bare and covered electrodes, bare welding wire, strip electrodes, welding flux, powdered filler metal, and hot rolled rod and wire are procured, warehoused, and shipped. 25 The operation includes procurement, receiving verification, warehousing, labeling, packaging, alloy identity testing as applicable, inspection and final acceptance testing as applicable. Per

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Scope and Applicability

ASME Code Section III, this is done as a Material Organization, and material is purchased from Material Organizations or source material is purchased from Approved Suppliers, and controlled under provisions necessary to assure compliance with the ASME Code Section III. See Section 0.4, "Procurement and Supply of Tubular and Welding Products per ASME Code Section III from 5

other Material Organizations" of this Manual.

Welding materials manufactured, supplied and shipped by Sandvik Materials Technology are processed and inspected according to the requirements of applicable ASME Codes, and AWS specifications, or other required standards or customer specifications.

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The Quality Policy of Sandvik Materials Technology reads: “Our key directive is complete customer satisfaction. We provide our customers with products and services that conform to all requirements. We will develop quality objectives at appropriate levels to ensure those requirements are effectively 5

addressed in our business. We are fully committed to continuous improvement as a strategic approach to achieve these quality objectives. Our policy and associated quality objectives are reviewed and communicated to all employees on a regular basis." This policy is based in its entirety on the AB Sandvik Materials Technology, Sweden

10

Corporate Quality Policy.

This policy is defined by the Company’s Executive Management and is considered relevant to Sandvik Materials Technology’s organizational goals and the needs and expectations of all customers. 15 The system for causing quality shall be prevention rather than appraisal and defect detection. All employees are encouraged to pursue never-ending improvement in quality. To support Sandvik’s quality objective and policy, Quality System Programs and action plans for continuous quality improvement shall be established within each Product Area of Sandvik Materials Technology. These 20

systems and action plans shall be commensurate with the products and services supplied by the Product Areas.

Sandvik Materials Technology’s Executive Management shall ensure that this policy is understood, implemented and maintained at all levels of the organization. 25 This Quality Manual describes and summarizes Product Area Tube's and Product Area Wire's Quality System Program for manufacturing and supplying of tubular products and welding materials in

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accordance with the Quality System Program's requirements of ASME Code Section III NCA-3800 and 10CFR50, Appendix B, and products requirements per ASME, ASTM and AWS specifications, and other standards.

5

This Quality System Program shall remain in effect as long as Sandvik Materials Technology shall manufacture and supply materials and products meeting the requirements of ASME Code Section III and above identified Quality System Programs standards.

Further, the Manual describes the responsibilities of the Quality and Metallurgy Function and other 10

functions involved in the execution of the Quality System Program. The intention is also to give information on the Company's policy in quality matters and describe the resources available for quality assurance, testing, examination, and inspection. For internal use, there are detailed Control Procedures and Instructions and Operating Directives and Instructions available, which deal with the distribution of responsibility of individuals in the organization as well as work functions attached to

15

product and service quality within Sandvik Materials Technology.

The Quality System Programs defined in this Manual are supported by all levels of Management within Sandvik Materials Technology. The Director/Manager, Quality and Metallurgy, has the final authority and the responsibility to approve and implement the Quality System Programs defined in the 20

Manual.

All persons or groups given duties and responsibilities by this Manual or its supporting procedures shall carry out those duties and responsibilities as the Manual or procedures describe.

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In the event of conflict between the Quality and Metallurgy Function and other functions, the problem shall be referred to the next higher level of Management for resolution. The resolution shall not be in conflict with the ASME Code Section III, other applicable standards, or this Manual. 5

P. Frosini President, Sandvik Materials Technology Date: 04/08/2009

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Quality and Metallurgy Function All levels of management within Sandvik Materials Technology have given the Quality and Metallurgy Function the authority, responsibility and freedom to: A. Initiate action which results in solutions to prevent the occurrence of any nonconformities relating 5

to product, process and quality system. B. Identify and record any quality problems related to product, process and quality system. C. Initiate, recommend or provide solutions through designated channels. D. Verify the implementation of solutions. E. Control further processing and delivery of nonconforming product until the deficiency or

10

unsatisfactory condition has been corrected.

The Quality and Metallurgy Function, upon notification by the inspectors or for any justifiable reason, has the authority to stop work for any production activity which may be in noncompliance with the established requirements. 15 The Director/Manager, Quality and Metallurgy is responsible for the Quality and Metallurgy Function and for the overall management of the Quality Systems in an effective and economical manner. He reports to the President, Sandvik Materials Technology.

In this function, he is sufficiently

independent from the pressure of production. He has direct access to the management level where 20

appropriate action can be initiated, and he reviews and reports regularly on the adequacy and effectiveness of the Quality Systems. He is also responsible for the development, issuance and implementation of quality policies, instructions and procedures necessary to comply ASME Code Section III requirements, and any other quality requirements.

25

The Director/Manager, Quality and Metallurgy is also responsible for the issuance of quality system procedures in the form of Control Procedures and Instructions and assures that all procedures and methods comply with customer order(s) and ASME Code Section III requirements and are in line with the established quality policy stated in this Manual. He is also responsible for monitoring of the

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inspection, testing, and examination functions and the control and issuance of Certified Material Test Reports.

It is the responsibility of the Product Area Quality Professionals and Technicians to assist the 5

Director/Manager, Quality and Metallurgy with the above functions and to investigate customer complaints, evaluate customer orders and specifications, maintain the status of rejected material, and report all discrepancies encountered to the Director/Manager, Quality and Metallurgy.

The Director/Manager, Quality and Metallurgy and the Product Area Quality Professionals have the 10

right to delegate quality assurance activities to qualified individuals within the Quality Assurance function.

The Director/Manager, Quality and Metallurgy is responsible for the operation of the Materials Laboratory and the Material Certificate Processing. The Materials Laboratory personnel establishes 15

test methods for accurate chemical analysis and physical testing. He supervises the

Materials

Laboratory Group Leader/Supervisor who manages the Materials Analyst(s) and Metallographer for performance of chemical and physical testing.

If the NDE Professional is a Sandvik Materials Technology employee, the Nondestructive Testing 20

Engineering function shall be responsible for SNT-TC-1A Level III activities.

The testing and inspection personnel are responsible for the performance of tasks as defined in the Control Procedures and Instructions. This includes recording of results of all tests and examinations performed. 25

They are also responsible for performing work in a manner as directed by the

Director/Manager - Quality and Metallurgy. While testing and inspection personnel are responsible for the performance of many Quality and Metallurgy Functions, The Director/Manager - Quality and Metallurgy retains the responsibility for final acceptance of the finished material and products and for auditing or otherwise verifying the execution of Quality and Metallurgy Functions.

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Sandvik Materials Technology Management has given the above personnel authority and freedom required to carry out the responsibilities defined per above. However, the direct responsibility for the quality of the finished material and products for individual orders lies with the Production 5

Departments.

Non-Quality and Metallurgy Function Personnel It is the responsibility of persons in departments other than the Quality and Metallurgy Function to 10

assist in the implementation of actions required to assure compliance with the established Quality System.

It shall be the responsibility of personnel in Purchasing, Production Control and Inventory Control functions to implement the requirements set forth by Quality Assurance in matters pertaining to 15

procurement of materials, services and manufacturing supplies to insure compliance with the necessary quality requirements.

It shall be the responsibility of personnel in the Production and Traffic Departments to coordinate and implement the requirements set forth by with Quality Assurance to insure manufacturing processes 20

and material handling are carried out in accordance with established Control Procedures and Instructions.

It shall also be the responsibility of personnel in any function to report conditions adverse to the quality to the Director/Manager, Quality and Metallurgy, whenever such conditions exist. 25 Personnel assigned responsibilities within the Quality System may delegate the performance of the involved activities to qualified personnel within the same department.

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Resources Resource requirements are identified by Sandvik Materials Technology’s executive management staff, who also shall provide adequate and trained resources for management, performance of work and verification activities including internal quality audits. The basis for evaluating needed resources 5

shall include but may not be limited to the implementation and continued effectiveness of the quality management system, ongoing compliance with customer requirements, and enhanced customer satisfaction.

Verification of Code activities shall be carried out by personnel independent of those having direct 10

responsibility for the work being performed.

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Sandvik Materials Technology The organization of the main functions of Sandvik Materials Technology is outlined in the organization chart below:

Sandvik AB Sandviken, Sweden

President AB Sandvik Materials Technology Sandviken, Sweden

President Sandvik Materials Technology-NAFTA Scranton, PA

Product Area Tube Production Unit Scranton, PA

Product Area Tube NAFTA Sales Unit Scranton, PA

Product Area Wire Scranton, PA

Human Resources

Quality & Metallurgy

Finance & Admin., Central Purchasing, Traffic, Central, Stores

Information Technology

Product Area Strip Scranton, PA

Strip Products Benton Harbor, MI Spring Products Scranton, PA

Product Area Strip are not covered by this Manual

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Product Area Tube The organization of the Product Area Tube Sales Unit is outlined in the organization chart below: President Sandvik Materials Technology - NAFTA Vice-President/General Manager Product Area Tube Tube Americas Scranton, PA

Sales & Marketing Manager Special Products

Sales Operations & Logistics Manager Scranton, PA

Product Managers Special Products Houston, TX

NADC Flow Supervisor Scranton, PA

Materials/ Inventory Control

Warehouse Operations Scranton, PA Sales Operations Supervisor

Warehouse & Logistics Manager Houston, TX

Vice-President Finance and Administration Salers Operations Scranton

Warehouse Operations HTDC Houston, TX

Sales Operations Houston

Controller (Shared W/ Production Unit) Scranton, PA

Manager Distribution & Value Added Services Houston, TX

Product Managers Houston, TX

Staff Accounting

Product Specialist Houston, TX

Sales Manager Standardized Products Scranton, PA

Quality Manager Tube SU/PU Scranton, PA

Product Manager Hollow Bar and Bar

Product Manager High Temperature

Product Manager Ethylene

Product Manager Heat Exchanger

Inside Sales Manager Scranton, PA

Inside Sales Scranton, PA

Director, Quality & Metallurgy

Quality Professional HTDC Houston, TX

Quality Technician Tube PU/SU Scranton, PA

Quality Professional Tube PU Scranton, PA

Outside Sales Manager East

Inside Sales Houston, TX

Outside Sales Manager West

Outside Sales Manager Central and Western Canada, West Coast,

Sales Manager Complementary Products Houston, TX

Outside Sales Eastern Canada, Southeast Northeast, Midwest New Business Development Manager Houston, TX

Applications Engineer Refinery Houston, TX

Applications Engineer Nuclear Houston, TX

Applications Engineer Automotive

Applications Engineer Oil & Gas Houston, TX

Key Account Manager Oil & Gas, Bar Houston, TX

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The organization of the Product Area Tube Production Unit is outlined in the organization chart below:

President Sandvik Materials Technology

Scranton, PA Director/Manager Quality & Metallurgy Vice-President Finance and Administration

Production Unit General Manager

Controller

Material Manager

Product Planning

Production Manager

Maintenance Supervisor

Maintenance

Quality Manager Tube Sales Unit/Product Unit

Flow Managers

Production

Quality Professional Tube Product Unit

Quality Technician Tube Sales Unit/Product Unit

Inspection and Testing

Process Engineer

Communications Manager Tube Product Unit

Production IT Analyst

Legend: Functional/Technical Reporting Administrative Reporting

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Product Area Wire and Heating Technology The organization of the Product Area Wire and Heating Technology is outlined in the organization chart below: President Sandvik Materials Technology - NAFTA

Vice-President/General Manager Product Area Wire Scranton, PA

Director/Managaer Quality & Metallurgy

Production Manager

Materials Manager/Supervisor

Lead Facilitator Dry Draw

Engineering Manager

Inventory Control

Materials Procurement

Planning Dry Draw

Process Manager

Maintenance

Flow Manager Wire Finishing

Wire Finishing Manager Marketing and Business Adminstration

Inside Sales & Customer Service Manager/Supervisor

Customer Service

Division Controller

Program Management

Inside Sales

Product Manager Consumer Goods

Key Accounts Manager Manager Technical Marketing

Product Manager Energy

Sr. Quality Specialist

Weld Laboratory

Inspection and Testing

Vice-President Finance & Administration

Manager Field Sales

Outside Sales Legend: Functional/Technical Reporting Administrative Reporting

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RESPONSIBILITY AND ORGANIZATION

Section: 1.3.3 Issue: 3 Revision: 1 Date: 01/03/2011

Organization – Organizational Charts Page: 5

Of: 6

Quality and Metallurgy Function The Quality and Metallurgy Function is composed of the Quality Assurance Department, the Materials Laboratories and the Certificate Processing group.

Quality activities for the Spring Products Division in Scranton, Pennsylvania, and the Product Area Strip in Benton Harbor, Michigan are part of the Quality and Metallurgy Function, but are not applicable to the ASME Code Section III requirements per this Manual.

The main objectives of the Quality and Metallurgy Function is to develop, implement and maintain Quality Systems to assure the Company's ability to manufacture and supply tubular products, wire products, and welding materials; meet applicable codes, standards and customer requirements; and to manage and facilitate the company’s continual quality improvement process. The activities related to quality assurance are carried out and executed by the Director/Manager, Quality and Metallurgy, Product Area Quality Professionals, the materials laboratory personnel, the material certificate processing personnel, and the testing and inspection personnel.

The organization of the Quality and Metallurgy Function is outlined on the following page.

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Section: 1.3.3 Issue: 3 Revision: 1 Date: 01/03/2011

RESPONSIBILITY AND ORGANIZATION Organization – Organizational Charts

Page: 6

Of: 6

Quality & Metallurgy Function Organization President Sandvik Materials Technology - NAFTA Director/Manager Quality & Metallurgy

Safety & Environmental Manager

Quality Assurance

Quality Managers/Specialists: Product Area Wire

Inspection and Testing

Spring Products

Quality Manager Tube SU/PU

Quality Technician Tube SU/PU

Strip Products

Materials Laboratory Group Leader/Supervisor

Quality Engineer Tube PU Scranton, PA

Inspection and Testing Quality Engineer Tube SU Houston, TX

Occupational Health & Safety Specialist

Manager Quality & Technology Product Area Strip

NDE Professional (1)

Materials Laboratory

Material Certificate Processing Personnel

Materials Analyst(s) Metallographer (1) The Level III activities may be addressed as a separate position within the Quality Assurance Department. The level III activities may also be incorporated into a specific position within the Tube Production Unit. If the position is located within the Tube Production Unit, the position shall report to the Director/Manager - Quality and Metallurgy or designee on NDE issues. An approved subcontractor may also provide this function as necessary.

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RESPONSIBILITY AND ORGANIZATION

Section: 1.3.4 Issue: 3 Revision: 0 Date: 04/08/2009

Organization - Management Review Page: 1

Of: 2

The Director/Manager, Quality and Metallurgy shall review yearly the adequacy of the entire Quality System Program and submit a report about this adequacy to the President, Sandvik Materials Technology.

This summary report shall be based on regular cross-functional product area

management review(s) performed by each Product Area. In addition, Sandvik’s executive 5

management is kept informed on the status, adequacy and effectiveness of the Quality System Program by: A. Personal communication with Director/Manager, Quality and Metallurgy, and other personnel directly involved in carrying out the Systems. B. Review of internal audit reports, including any trends by element.

10

C. Review of the results of customer/third party audits. D. Review of customer feedback including complaints. E. Review of corrective action reports and trend analyses. F. Review of preventive action activities. G. Review of Quality System Program elements.

15

H. Process performance results and scrap and rework trends. I.

Follow-up actions from previous management reviews.

J.

Changes that could affect the quality management system.

K. Recommendations for improvement.

20

Sandvik executive management, under the direction of the President, Sandvik Materials Technology, shall annually review and document the adequacy and effectiveness of the Quality System Program to ensure their continuing suitability and effectiveness in satisfying the requirements of ASME Code Section III and the Company’s Quality Policy and Objectives. This review shall be based on the information as outlined above and documented in a separate report by the President.

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RESPONSIBILITY AND ORGANIZATION

Section: 1.3.4 Issue: 3 Revision: 0 Date: 04/08/2009

Organization - Management Review Page: 2

Of: 2

At a minimum, the outcome of the management review shall include: A. Modifications/improvements of the Quality System Program and its associated processes, as needed. 5

B. Improvements to customer-related product improvements/enhancements. C. Modifications/reevaluations of required resources. D. Action(s) to ensure compliance with customer requirements, product/process improvements, and quality management system improvements. Modifications of the Quality System Program, if needed, shall be made based on this review. Any

10

inadequacies or discrepancies found during the Management Review process shall result, at the discretion of the Director/Manager - Quality and Metallurgy, in the issuance of Corrective Action(s). The Director/Manager, Quality and Metallurgy shall notify ASME of proposed modifications for approval prior to their implementation.

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QUALITY MANUAL ASME Code Section III

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PERSONNEL

Section: 2.1 Issue: 3 Revision: 0 Date: 04/08/2009

Indoctrination, Training, and Qualification of Personnel Page: 1

Of: 2

The Quality and Metallurgy Function is responsible for identifying and assuring that the personnel in the Quality Assurance Department, the Materials Laboratory, the Welding Laboratory, and the Material Certificate Processing Group are properly trained and qualified. This training shall be documented. It shall be the responsibility of the Director/Manager, Quality and Metallurgy to see 5

to it that adequate training in the Quality System Program is provided to Sandvik personnel.

Quality and Metallurgy personnel are selected by management on the basis of their qualifications and their capabilities of maintaining acceptable level of performance.

10

In processing of tubular and welding products and welding materials. it has been observed that, for newly-employed personnel, on-the-job training is very effective. Newly employed personnel also undergo a format orientation program developed and conducted by an internal orientation training group.

15

The managers of other departments responsible for the execution of functions affecting product quality will be responsible for identifying the relevant personnel and assuring that those relevant personnel in these functions are properly trained, including indoctrination training. This training shall be documented. These operations and techniques will be subject to internal audit review to assure the functions are executed in an effective manner.

20 Personnel responsible for nondestructive examination are qualified and certified by the Level III person and the Director/Manager, Quality and Metallurgy, per the approved Written Practice in accordance with the applicable edition of SNT-TC-1A, as specified by the Code, and the Code. See Section 8.1.2, "Inspection, Examination, and Test Control - Testing" of this Manual. The 25

Written Practice is documented in a Control Procedure and Instruction.

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PERSONNEL

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Indoctrination, Training, and Qualification of Personnel Page: 2

Of: 2

The Sandvik Level III is qualified by examination and certified by the Director/Manager, Quality and Metallurgy in accordance with the requirements of the Written Practice. The Level III is appointed by letter, signed by Director/Manager, Quality and Metallurgy.

5

The Level III shall certify Level I and Level II examiners. Record of qualification/certification of nondestructive examination personnel are specified in the Written Practice and maintained by the Director/Manager, Quality and Metallurgy.

The Director/Manager, Quality and Metallurgy (or designee) is responsible for the periodic 10

training of non-quality assurance personnel in matters relating to product quality and the Quality System Program. The training is performed in the form of meetings and seminars.

Scheduled training of all employees in subjects related to Sandvik Materials Technology's Continuous Quality Improvement Process is performed by qualified and certified internal trainers. 15 The effectiveness of the training given to all employees shall be regularly evaluated per an established Control Procedure and Instruction.

Training and indoctrination records shall be maintained per Section 2.2, "Personnel Records" of 20

this Manual.

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PERSONNEL

Section: 2.2 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 1

Of: 1

Personnel Records

Personnel records required by ASME Code Section III are maintained by the Director/Manager, Quality and Metallurgy.

These records consist of personnel (Sandvik and subcontractors)

qualifications for non-destructive examinations per the approved Written Practices in accordance with SNT-TC-1A (edition as specified in the Code) 5

Records of qualification/certification of

nondestructive examination personnel are specified in the Written Practice and maintained by the Director/Manager, Quality and Metallurgy.

Records of qualification/certification of lead auditors personnel are maintained by the Director/Manager, Quality and Metallurgy. 10 Quality Assurance shall also maintain other personnel records for qualification of personnel within Sandvik in matters pertaining to product quality and the Quality System Program.

Personnel records are available for review within the Quality Assurance Department. 15 Records for training in the Quality System Program are maintained by Quality Assurance and these records shall show subject covered, duration of training session, attendee, name of instructor and date.

20

The Human Resources Department maintains personnel records related to job content and job descriptions. The majority of these records are maintained electronically.

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PROGRAM DOCUMENTATION

Section: 3.1 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 1

Of: 1

Quality Manual

Sandvik's Quality System Program has been established and documented in this Quality Manual to verify that all requirements per the Code and of material and product specifications and customer requirements have been met and to provide control over these functions affecting quality during manufacturing, storage, handling and supply of material and products. 5 The Quality System Program provides for control of material and service procurement, order processing, customer order and specification review, testing and inspection equipment and procedures, as well as material and product traceability and identity. The Quality System Program also provides for control of nonconforming material, corrective action, quality assurance records, 10

special processes, audits and Code-required documents.

The Director/Manager, Quality and Metallurgy, has the responsibility to establish a quality organization and implement the Quality System Program described in this Quality Manual.

15

The Quality Manual is issued, revised and controlled by the Director/Manager – Quality & Metallurgy in accordance with Section 3.3, "Document Control" of this Manual.

The following Section 3.2, “Procedures, Instructions, and Drawings” of this Manual outlines the structure of the documentation used in Sandvik’s Quality System Program. 20

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PROGRAM DOCUMENTATION

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Date: 04/08/2009

Page: 1

Of: 2

Procedures, Instructions, and Drawings

General The structure of quality system program procedures and the documentation used in the Quality System Program is as follows: --- Quality Manual 5

--- Control Procedures and Instructions --- Operating Directives and Instructions -- manufacturing work instructions --- Laboratory Procedures and Instructions

These documented procedures are prepared to be consistent with the Quality System Program and 10

with the requirements of ASME Code Section III, and customer order requirements.

Control Procedures and Instructions For control of operations, materials and products, and for implementation of the Quality System Program, Control Procedures and Instructions are maintained as part of the Quality System Program. 15

The Director/Manager, Quality and Metallurgy, is responsible for issuance, revision and control of these Control Procedures and Instructions, which internally are commonly referred to as CPI’s. They describe the activities affecting quality and the elements in the Quality Systems, and are issued, revised and controlled in accordance with Section 3.3, “Document Control” of this Manual.

20

Acceptance levels involved in these detailed Control Procedures and Instructions are set by Quality Assurance in order to meet ASME Code Section II and ASME Code Section III, ASTM and AWS, specifications and other standards, as well as customer specifications.

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Date: 04/08/2009

Page: 2

Of: 2

Procedures, Instructions, and Drawings

Operating Directives and Instructions Work instructions are documented in Operating Directives and Instructions. The production departments are primarily responsible for the development and revision of these documents, which internally are commonly referred to as ODIN’s. 5

Quality Assurance is responsible for issuance and

for control of these documents in accordance with Section 3.3, “Document Control” of this Manual.

Laboratory Procedures and Instructions Laboratory Procedures and Instructions (commonly referred to as LPI’s) are issued, revised and controlled by the Materials Laboratory personnel in accordance with Section 3.3, “Document Control” 10

of this Manual.

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PROGRAM DOCUMENTATION

Section: 3.3 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 1

Of: 5

Document Control

At Sandvik, activities affecting quality are prescribed by and performed in accordance with documents.

These documents are issued and controlled by Quality Assurance: this Quality Manual, Control 5

Procedures and Instructions (CPI), Materials Specifications (MS), Laboratory Procedures and Instructions (LPI), Operating Directives and Instructions (ODIN), Process Control Plans and Process Outlines. Documents are distributed to and used at the location where the activity is performed and invalid and/or obsolete documents are promptly removed from all points of issue or use.

10

The Director/ Manager, Quality and Metallurgy, is responsible for the preparation, issuance, revision and approval of this Quality Manual.

The Quality Manual is issued on a controlled basis to persons in the Sandvik Materials Technology organization, and to ASME. Distribution of the Quality Manual to other persons outside Sandvik 15

Materials Technology will be on an uncontrolled copy basis unless a controlled copy is specifically requested and the request is approved by Director/Manager, Quality and Metallurgy or designee.

Review of Code editions and addenda will be performed on an annual basis.

The review and

necessary changes to the Manual shall be made within six (6) months of the "date of issue" of the 20

Code edition or addenda. This review shall be documented by the Director/Manager, Quality and Metallurgy, in writing showing each edition or addenda and paragraph reviewed. When deemed necessary, changes will be made to the Manual and submitted to ASME for approval prior to implementation.

25

When revisions are required to this Quality Manual, they shall be made by section, except for the list of Forms and Document section, which shall be revised by the exhibits and the revision identified on the exhibits and the list of forms and documents.

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Section: 3.3 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 2

Of: 5

Document Control

When a change is made, the area of applicable paragraph shall be highlighted by a vertical line in the margin (|) adjacent to the revision.

The entire section shall carry the next higher revision number.

The Quality Manual table of contents shall show the current revision number, the date, and the approval of the Director/Manager, Quality and Metallurgy. In addition, the cover page of the Quality 5

Manual shall carry the current revision number and date. Forms exhibited in the Quality Manual shall be controlled by the List of Forms and Documents, which defines each exhibit by number, title, revision and date of revision.

Each revision of the Quality Manual shall be submitted to the ASME and their acceptance attained 10

prior to issue and implementation of the changes. Exhibits may be revised and implemented prior to ASME acceptance provided they contain at least the same information as the superseded exhibit. Sandvik Materials Technology shall implement changes within thirty (30) days of receipt of ASME acceptance.

15

Issuance of controlled copies of the Quality Manual will be recorded in a Quality Manual distribution log which will be maintained by Quality Assurance.

This distribution log shall show the Quality

Manual number, to whom issued, revision number, issuance date and date of acknowledgment. This log shall also verify that the revision issuance was not made prior to ASME acceptance.

20

Uncontrolled copies of the Quality Manual may be issued outside the Sandvik Materials Technology. An uncontrolled copy shall be current as of the date of issuance, but shall not be maintained nor shall such issuance be logged unless required by Quality Assurance.

Controlled Quality Manuals and revisions will be issued through the use of Quality Manual 25

acknowledgment letter (EXHIBIT 6), which shall require acknowledgment of receipt of the Quality Manual or the revised pages. For Quality Manuals held by persons outside of Sandvik Materials Technology, revisions may be mailed with postal return receipt requested. Acknowledgment and return receipts shall be filed by Quality Assurance. Use of postal return receipt does not apply to the

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Date: 01/03/2011

Page: 3

Of: 5

Document Control

ASME copy. For Quality Manuals held by Sandvik Materials Technology personnel, acknowledgment must be received within seven (7) days or a personal follow-up shall be made by the Product Area Quality Professional (or his/her designee). When Quality Assurance determines that reason for the acknowledgment of receipt not being returned is unacceptable, a corrective action shall be issued per 5

Section 14, "Corrective Action", of this Manual.

The Control Procedures and Instructions (CPI) are always approved by the Director/Manager, Quality and Metallurgy, and issued and controlled by the Product Area Quality Professional. The primary method for issuing and controlling Control Procedures and Instructions (CPI) is electronically. 10

Revisions or changes are approved and controlled in the same manner as the initial procedure. When the CPI distribution and control is maintained through electronic means, the signing and dating of the master index is not required. There is no need to acknowledge receipt of electronic documents since the distribution/receipt is automatically controlled by the system. Hard copies of these CPI's shall be issued to numbered controlled books assigned to individuals, or as partial books assigned to

15

specific work stations, controlled by the CPI Holders List and Table of Contents for each book. The CPI Table of Contents lists all Control Procedures and Instructions by CPI number, revision level and issue date. When partial books are issued, the number of the partial book from the Holders List shall be referenced next to those Control Procedures and Instructions which are to be present in the particular partial books. Hard copies of all Control Procedures and Instructions are stamped with a

20

"Controlled Document" stamp with the following text: "Controlled document only if this stamp is in original red ink". New and revised Control Procedures and Instructions are hand delivered by the Product Area Quality Professional or designee and superseded revisions and obsolete copies are deleted and destroyed by the Product Area Quality Professional or designee. In order to ensure the presence of the entire document, the approval section, which by default is at the end of the

25

document, of the CPI shall be present. This will indicate that all of the documents pages are present. If the CPI distribution and control is maintained through electronic means, access to specific documents will be done through system security and access controls designated by Quality

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Page: 4

Of: 5

Document Control

Assurance. The Quality Assurance person making the distribution shall sign and date the master CPI index to indicate the distribution has been completed.

Material Specifications (MS) for procurement of source material and material for tubular products and 5

for welding products, are written by the Product Area Quality Professional or Wire Technical Marketing personnel and reviewed and approved by the Director/Manager, Quality and Metallurgy or his/her designee. They must also be approved by managers of all departments affected by the specification. MS's are issued and controlled by the Product Area Quality Professional. These MS's are issued on a controlled basis only, and any revisions are issued solely by the Product Area Quality

10

Professional. The primary method for issuing and controlling Material Specifications is electronically. Revisions or changes are approved and controlled in the same manner as the initial procedure. If the MS distribution and control is maintained through electronic means, access to specific documents will be done through system security and access controls designated by Quality Assurance. They shall be issued to numbered controlled books assigned to individuals and are controlled by the MS index

15

and Table of Contents. In order to ensure the presence of the entire document, the approval section of the MS shall be present. This will indicate that all of the documents pages are present. The Quality Assurance person making the distribution shall sign and date the master MS index to indicate the distribution has been completed. If the MS distribution and control is maintained through electronic means, the signing and dating of the master index is not required.

20 Laboratory Procedures and Instructions (LPI) and changes are approved by the Materials Laboratory personnel. They are issued and controlled by the Materials Laboratory personnel. They cover in detail the work to be performed in the Materials Laboratory for chemical analysis and acceptance testing of source material and material. These LPI's shall be issued to numbered controlled books to 25

individuals and are controlled by the LPI index and table of contents. In order to ensure the presence of the entire document, each LPI shall indicate the total number of pages. The person making the distribution shall sign and date the master LPI index to indicate the distribution has been completed.

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Section: 3.3 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 5

Of: 5

Document Control

Operating Directives and Instructions (ODIN) and their changes are written by any responsible employee.

They are reviewed and approved by the Product Area Quality Professional, and by

managers of all departments affected by the ODIN. The control, issuance and distribution of ODIN's are made by Quality Assurance in the same way as for CPI's. 5 Process Control Plans/Quality Control Plans and their changes are prepared by the Product Area Quality Professional and issued by Quality Assurance to those functions affected by the documents. Hard copies of the work order (shop traveler) are generated from the mainframe computer system. In 10

order to ensure the presence of the entire work order (shop traveler), the last page shall state “END” or “END OF TRANSMISSION” or “END OF REPORT”.

National and international standards such as ASTM, ASME, and AWS specifications shall be controlled by Quality per applicable Control Procedures and Instructions. When distributed outside of 15

Quality Assurance, controlled standards shall be assigned a controlled copy number and shall be stamped "Controlled Document" on the title page. A current list of holders of controlled standards shall be maintained by QA. Quality Assurance shall be responsible for review of applicable parts of these standards, for availability of these standards where needed, and for assuring that superseded standards are not used for product inspection, testing and acceptance.

20 Any obsolete documents retained for legal and/or knowledge-preservation purposes shall be suitably identified.

Documents and data can be in the form of hard copies or electronic media. When

electronic media is used, Control Procedures and Instructions (CPI’s) shall be established to control all electronic media documents.

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Date: 04/08/2009

Page: 1

Of: 3

Quality Assurance Records

Records are prepared to furnish documentary evidence of the quality of material and products and of activities affecting quality. It is Sandvik's policy to maintain these records for a certain period of time, established by an approved Control Procedure and Instruction.

5

Records to be prepared, controlled, and maintained, including the retention time and disposition, for each type of record are specified in a Control Procedure and Instruction. The following records will be maintained: inspection records, test records, personnel qualification records, calibration records, process qualification records for specific processes, Control Procedures and Instructions, Laboratory Procedures and Instructions, Operating Directives and Instructions, order

10

review records, supplier audit records, internal audit records, nonconforming product records, product identification records, corrective action records, management review records, training records.

Quality records shall be legible, identifiable, and retrievable. 15 Inspection, examination, and test records are maintained and are traceable to the original material or product. These records include but are not limited to: receiving, in-process and final inspection and testing records.

20

Test reports submitted by subcontractors, independent testing laboratories and all material manufacturers are compiled and maintained traceable to the original material.

Quality records shall be retrievable and be stored and maintained in a suitable environment to minimize deterioration or damage to prevent loss. 25 Certain quality documents, such as Certified Material Test Reports and calibration records, are created by restricted access to a computer system. Computer security features include the following controls:

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Of: 3

Quality Assurance Records



Access to the system is controlled by user identification in conjunction with a user maintained password.



Access to each system menu is restricted by user identification.



Resource security restricts access to individual files. Various access levels are defined by

5

user identification. •

Access to the system is established by the Director/Manager – Information Technology in conjunction with Management. The Director/Manager – Information Technology reports to the President – Sandvik Materials Technology, Scranton, PA.

• 10

The Director/Manager – Information Technology is the only individual who has access to the system security file.



The system requires each user to change his or her password at a set frequency in days as defined by the Director/Manager – Information Technology.



The system does not allow for a user to sign on to more than one device; it is against established company policy for a user to give out passwords to others.

15



The system automatically logs off any user who has left his/her terminal signed on unattended for more than 60 minutes.



The system automatically locks out the device if a user inputs three (3) incorrect passwords.



Access to the Information Technology Department is protected by a door lock security code system.

20 Certain quality documents, such as Quality System Program documentation, nonconforming material reports and corrective actions, are created by restricted access to a computer system. Computer security features include the following controls: • 25

Access to the system is controlled by user identification in conjunction with a user maintained password.



Access to each system menu is restricted by user identification.

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Quality Assurance Records



Resource security restricts access to individual files. Various access levels are defined by user identification.



Access to the system is established by the Director/Manager – Information Technology in conjunction with Management.

5



The Director/Manager – Information Technology is the only individual who has access to the system security file.



The Information Technology Department is protected by a door lock security code system.

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Section: 3.5 Issue: 3 Revision: 0

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Page: 1

Of: 2

Records of Examinations and Tests

General Records for inspection, examinations and tests are signed and dated or entered into a secure computer system by the individual who performed the activity to verify that the activity was performed and that the result of the activity was acceptable. These records are reviewed and 5

approved by the Product Area Quality Professional (or designee) to verify that all characteristics required to be reported by the material specification and ASME Code Section III are recorded and within specified limits as specified on the Product Requirement Review Sheets (EXHIBITS 2 and 3). The Product Area Quality Professional (or designee) sign and date the Laboratory Test Reports (EXHIBIT 14).

10 Test results related to sales orders involving only destructive tests of material are recorded on the Laboratory Request Item form (EXHIBIT 4). Once the results of testing are recorded on the Lab Request Item form, it is sent to the requestor. If acceptable, the results of this testing are entered into the mainframe test results computer file by lot order and heat number. The Product Area 15

Quality Professional (or his/her designee) will enter the test result(s) into the mainframe test results database along with the Lab Request Item number and his/her initials.

Records are traceable through sales order, work order and/or lot number as applicable to material specification and to procedure and revision to which inspection and testing is to be 20

performed, including acceptance criteria.

Pipe and Tube Separate inspection forms are used for each work order indicating the status of eddy current testing (EXHIBIT 15), ultrasonic testing (EXHIBIT 16) and final inspection (EXHIBIT 11). Results 25

from destructive testing performed in the Materials Laboratory are recorded on the Laboratory Test Report (EXHIBIT 14) for each work order. This report is signed and dated by the Product Area Quality Professional (or his/her designee).

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT ARE TUBE * * * PRODUCT AREA WIRE

PROGRAM DOCUMENTATION

Section: 3.5 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 2

Of: 2

Records of Examinations and Tests

Welding Material Different forms are used for each work order to indicate the status and to record the results of inspection and testing and with space for recording results.

5

EXHIBIT 21 is used for in-process and final inspection of bare electrodes and rods to be cut by Sandvik Materials Technology.

Results of weld testing and chemical and physical testing are recorded on the Laboratory Request Item form (EXHIBIT 4).

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

CONTROL OF PURCHASE MATERIALS, SOURCE MATERIALS, AND SERVICES

Section: 5.1 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 1

Of: 1

General

Measures have been established to assure that all purchases material, source material, and subcontracted services conform to the requirements of the Code. These measures are intended to prevent the use of incorrect or defective material or source material including materials that have not been examined or tested to specified requirements. 5 Material or source material in either Product Area Tube or Product Area Wire is not repaired by welding.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

CONTROL OF PURCHASE MATERIALS, SOURCE MATERIALS, AND SERVICES Sources of Material, Source Material and Services Including Approval and Control of Suppliers of Source Material and Services Assessment and Approval of Material Organizations and Suppliers

Section: 5.2 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 1

Of: 4

Suppliers of source material, material, and services shall be selected on the basis of their ability to meet Sandvik's requirements. An Approved Suppliers List shall be established and maintained. For tubular products and welding and wire products per Code requirements, Quality Assurance establishes and maintains the Approved Suppliers List for ASME Section III and Military Applications. 5 The approval and control of Material Organizations, suppliers of source material, and suppliers of services per ASME Code Section III requirements shall be the responsibility of the Director/Manager, Quality and Metallurgy. The approval shall be based on an evaluation of the Material Organization’s or supplier's quality system program following a survey evaluated against applicable Code 10

requirements, or the Material Organization/supplier may be approved as an accredited Material Organization holding a valid ASME Quality System Certificate (Materials) on file at Sandvik. The survey of the Material Organization/supplier shall be performed by competent persons qualified and designated as lead auditors by the Director/Manager, Quality and Metallurgy (see Section 9.1 “Audits” of this Manual), and per an approved Control Procedure and Instruction requiring the use of

15

a checklist prepared by the Director/Manager, Quality and Metallurgy, or his designee. This checklist shall include the items relevant to the scope and type of material or services to be supplied. Within ten (10) working days of the survey, the lead auditor will issue a survey report with his recommendation. The Director/Manager, Quality and Metallurgy or designee will review the report and will approve or disapprove the Material Organization/supplier as appropriate. The notice of the

20

Material Organization/supplier approval by the Director/Manager, Quality and Metallurgy (Approved Suppliers List, maintained current) to other Sandvik personnel shall include the scope of material or service for which the Material Organization/supplier is approved, the address of the approved facility, the expiration date of an ASME certificate, if applicable, the due date of the next audit or performance assessment, the Material Organization/ supplier's Quality Manual, date and revision, approved by

25

Sandvik, and the limitation of scope.

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

CONTROL OF PURCHASE MATERIALS, SOURCE MATERIALS, AND SERVICES Sources of Material, Source Material and Services Including Approval and Control of Suppliers of Source Material and Services Assessment and Approval of Material Organizations and Suppliers

Section: 5.2 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 2

Of: 4

Disapproval of a current Material Organization/supplier will cause deletion from the Approved Suppliers List, but may be identified on the List cover page as "Disapproved Material Organization/Supplier" and with a statement that a new survey is required prior to re-approval.

5

Material Organizations/Suppliers may remain on the Approved Suppliers List after reaching the next audit due date. In this case, a new survey must be performed prior to placement of the next order. This is identified on the Approved Suppliers List by a statement that indicates that a re-survey is required.

10

After the initial survey and acceptance, the audit frequency of Qualified Material Organizations, approved suppliers of source material and services shall be commensurate with the schedule of production or procurement, but shall be conducted at least once triennially during the interval in which material is controlled or services are performed.

For Qualified Material Organizations and for

suppliers of source material, the triennial audits shall be supplemented with annual audits or 15

performance assessments documenting the effectiveness of the quality system programs.

The

performance assessment shall be initiated by the Director/Manager, Quality and Metallurgy and shall be conducted per an approved Control Procedure and Instruction annually during the interval in which materials or source materials and controlled.

20

The assessment shall include a documented review of the history of conditions adverse to quality, nonconformances, and corrective actions.

The assessment shall include documented review of

periodic testing performed by Sandvik since last assessment to demonstrate conformance of sample materials to selected requirements of the material specification.

25

All records for initial surveys, audits and performance assessments shall be kept by Quality Assurance.

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

CONTROL OF PURCHASE MATERIALS, SOURCE MATERIALS, AND SERVICES Sources of Material, Source Material and Services Including Approval and Control of Suppliers of Source Material and Services Assessment and Approval of Material Organizations and Suppliers

Section: 5.2 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 3

Of: 4

Accredited Material Organizations, approved based on their valid ASME Quality System Certificate, shall per Nuclear Regulatory Commission requirements, be evaluated annually by onsite audits or by performance-based inspection and testing of all product characteristics reported on the material certificate. 5 Qualified Material Organizations, and approved suppliers of source material shall notify Sandvik’s Director/Manager, Quality and Metallurgy, or his designee, of proposed modifications to the accepted Quality System Manual. This requirement shall be specified by Sandvik in the letter of approval to the Qualified Material Organization or approved supplier of source material. 10 As an alternative to approval by surveying and auditing, a supplier of subcontracted services may perform the activities in accordance with controls established by Sandvik Materials Technology in approved Control Procedures and Instructions, which shall be listed under the scope of approval on the Approved Suppliers List. 15 Suppliers of calibration and outside testing services shall be audited/evaluated by competent persons qualified and designated as lead auditors by the Director/Manager, Quality and Metallurgy, to verify the supplier's performance and that reference standards used are traceable to National Standards where such exist, or to the equipment manufacturer's standards. 20

This audit/evaluation shall be

documented and approved by the Director/Manager, Quality and Metallurgy. When the calibration service is supplied by the manufacturer of the measuring and test equipment, the audit/evaluation may be limited to verification of reference standards only, at the discretion of the Director/Manager, Quality and Metallurgy.

25

The audit frequency of calibration services and outside testing services shall be every three (3) years, with a yearly evaluation.

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

CONTROL OF PURCHASE MATERIALS, SOURCE MATERIALS, AND SERVICES Sources of Material, Source Material and Services Including Approval and Control of Suppliers of Source Material and Services Assessment and Approval of Material Organizations and Suppliers

Section: 5.2 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 4

Of: 4

As an alternative to survey and audit, suppliers of subcontracted calibration services may be accepted if they are accredited by either the National Voluntary Laboratory Accreditation Program (NAVLAP), American Association for Laboratory Accredition (A2LA), or other accrediting body recognized by NAVLAP through the International Laboratory Accreditation 5

Recognition Arrangement.

Cooperation

Mutual

The criteria for accreditation shall be ISO 17025:2005 – General

Requirements for the Competence of Testing and Calibration Laboratories. The published scope of the accreditation for calibration services to ISO 17025 shall cover the needed measurement parameters, ranges, and uncertainties.

The purchase order shall specify that the calibration

certificate or report include the identification of laboratory equipment and/or standards used and the 10

pre-calibration (as-received) and post-calibration (as-returned) data. The calibration certificate or report shall be reviewed and approved by Quality Assurance against the purchase order to ensure all requirements have been met.

Suppliers of survey and audit services shall be approved by the Director/Manager, Quality and 15

Metallurgy, based on his evaluation of their performance, education, training, and experience.

The evaluation frequency of suppliers of survey and audit services shall be every three (3) years.

Report of surveys, audits and evaluations indicating their acceptability and approval status shall be 20

maintained by Quailty Assurance.

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

CONTROL OF PURCHASE MATERIALS, SOURCE MATERIALS, AND SERVICES

Section: 5.4 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 1

Of: 2

Procurement Document Control

General Source material and services for tubular and welding products are purchased from approved suppliers and in accordance with specific requirements, included in or referenced on the procurement documents. 5 When the requirements for procurement of source material, material, and services are specified in Control Procedures and Instructions, or in Sandvik internal Material Specifications, the procedure or specification is referenced on the purchase order. The applicable Control Procedure and Instruction or Material Specifications and its revision shall contain, as applicable, requirements of chemical 10

composition, mechanical properties, production, service activities to be performed, and the quality system program approved by Sandvik and listed on the Approved Suppliers List for ASME Section III and Military Applications.

For Code material, the supplier shall certify the same.

The Control

Procedure and Instruction or Material Specification is approved by the Director/Manager, Quality and Metallurgy or his designee, per Section 3.3, "Document Control" of this Manual. 15 Product Area Tube and Product Area Wire Procurement documents for source material, material and subcontracted services are controlled for transmittal of necessary Code and customer requirements to assure compliance with ASME Code Section III. 20 This control is executed through internal specifications, which are used when Sandvik purchases source material and finished goods of Code material as a Material Organization.

These

specifications are originated by Sandvik Materials Technology in the form of approved Control Procedures and Instructions (CPI), or Material Specifications (MS). 25

They are designed to meet

requirements of applicable ASTM or AWS specifications as well as ASME Code, Section II and Section III. To supplement the use of Material Specifications, the original customer purchase order and associated documents may be transmitted to Material Organization manufacturing or supplying the material.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

CONTROL OF PURCHASE MATERIALS, SOURCE MATERIALS, AND SERVICES

Section: 5.4 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 2

Of: 2

Procurement Document Control

When the Sandvik internal specification is not sufficient to procure source material or material, the additional procurement information will be stated on the purchase order. In this case, these 5

procurement document shall be reviewed and approved by the Product Area Quality Professional to ensure all relevant information is present.

These services may include (but are not limited to) testing and manufacturing operations, such as grinding, slitting, cleaning and deburring. Purchase orders for subcontracted services are reviewed 10

and approved by the Product Area Quality Professional for completeness to assure that all Code and customer requirements are transmitted.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

CONTROL OF PURCHASED MATERIALS, SOURCE MATERIALS, AND SERVICES

Section: 5.5 Issue: 0 Revision: 0

Date: 04/08/2009

Page: 1

Of: 2

Utilization of Unqualified Source Material

Sandvik may, for Tubular and Welding Products, purchase and utilize unqualified source material not produced by a Material Organization or approved supplier in accordance with the requirements of ASME Code Section III, but produced by a supplier who provides a certification to the requirements of the material specification that were performed during melting, heat analysis, and heat treatment under the 5

following conditions: A. The supplier agrees in writing that no welding (with filler metal) was performed on the unqualified source material. B. For welding products, the supplier agrees that no welding without filler metal (splicing) was performed on unqualified source material.

10

C. Sandvik performs a product analysis for each piece of material to verify the chemical composition. D. Sandvik will perform all other requirements of the Material Specification on each piece of material. E. The unqualified source material supplier submits to Sandvik a material certificate including heat analysis and all other requirements that had to be performed during manufacturing.

15

The Product Area Quality Professional shall review the material certificate for compliance with applicable material requirements, and shall arrange for testing of product analysis and other requirements per the material specification on each piece of material per Section 8.1.2, “Testing” of this Manual.

Per ASME Code Section III, the Product Area Quality Professonal shall request testing for product 20

analysis and other requirements per the material specification by submitting a Laboratory Request Form (EXHIBIT 4) to the Materials Laboratory for each piece of unqualified source material to be tested. Samples are submitted to the Product Area Quality Professonal, who submits samples and request form to the Materials Laboratory. Laboratory personnel record the results on the form and return the form containing test results to the Product Area Quality Professonal. The Product Area Quality Professonal

25

reviews the test results for conformance to Code and material specification requirements, and, if acceptable, enters the test results into the mainframe test results system .

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

CONTROL OF PURCHASED MATERIALS, SOURCE MATERIALS, AND SERVICES

Section: 5.5 Issue: 0 Revision: 0

Date: 04/08/2009

Page: 2

Of: 2

Utilization of Unqualified Source Material

As an alternative to “D” above, Sandvik may perform or subcontract all other requirements of the material specification on each heat and lot of unqualified source material provided: 1. A Certified Material Test Report is provided with the unqualified source material. 2. The unqualified source material is traceable to the Certified Material Test Report. 5

3. Procurement documents require that suppliers of unqualified source material established written procedures for identifying source materials in a manner that provides traceability to the Certified Material Test Report. 4. Sandvik reviews and accepts the supplier’s identification and traceability procedures and verifies compliance with the procedures through an audit of identification and traceability at a frequency

10

commensurate with the schedule of production or procurement, but at least once triennially. 5. Upon receipt, Sandvik shall verify by review of objective evidence, that the requirements of the procurement document have been met.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

CONTROL OF PURCHASE MATERIALS, SOURCE MATERIALS, AND SERVICES

Section: 5.6 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 1

Of: 1

Verification of Purchased Material, Products and Services

For Sandvik Materials Technology manufactured product, customers shall be offered the right to access Sandvik's facilities or approved subcontractors' facilities when so specified in the contract.

When the customer or customer's representative elects to carry out source inspection/verification at 5

Sandvik's facilities, or at Sandvik's approved subcontractor's facility, such inspection/verification shall not absolve Sandvik from the responsibility to provide acceptable product, nor shall it preclude subsequent rejection.

Furthermore, the customer's inspection/verification shall not be used by

Sandvik as effective control of quality by the subcontractor.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

CONTROL OF PURCHASE MATERIALS, SOURCE MATERIALS, AND SERVICES

Section: 5.7 Issue: 3 Revision: 1

Date: 01/03/2011

Page: 1

Of: 1

Direct Shipment of Material from a Material Organization

When material, manufactured and certified by a Material Organization qualified by Sandvik Materials Technology is shipped directly (dropped shipped) to a customer, the final inspection shall be performed under the direction of an individual, qualified and appointed by the Director/Manager, Quality and Metallurgy. 5 The appropriate Product Area Quality Professional shall ensure that the material meets ASME Code Section III requirements and customer order requirements. The following measures shall be taken: •

Verification that the Material Organization is listed on the ASME Code Section III Approved Supplier Listing.

10



Verification that all ASME Code and customer order requirements have been forwarded to the Material Organization.



Verification that the material has been inspected under the direction of an individual, qualified and appointed by the Director/Manager, Quality and Metallurgy.

• 15

Verification that the Certified Material Test Report (CMTR) from the Material Organization is reviewed and approved by the Sandvik Materials Technology Quality Assurance Department. Verification, when appropriate, that the certificates from other approved suppliers for required chemical analysis (including melting mill heat analysis), heat treatments, tests and examinations are reviewed and approved by the Sandvik Materials Technology Quality Assurance Department.

• 20

Preparation of a Sandvik Materials Technology CMTR certifying conformance to the customer purchase order.

The Sandvik Materials Technology Quality System Certificate number and

expiration date shall be referenced. •

Transmittal prior to or at the time of the order shipment of the Sandvik CMTR including all approved certifications received from the Material Organizations and, when appropriate, approved suppliers for required chemical analysis (including melting mill heat analysis), heat

25

treatments, tests and examinations.

These certifications shall be furnished as an identified

attachment to the Certified Material Test Report. The purchase order to the material organization shall state that approval of the Certified Material Test Report is required by Sandvik Materials Technology prior to shipment.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

IDENTIFICATION, MARKING, AND MATERIAL CONTROL

Section: 6.1 Issue: 3 Revision: 0 Date: 04/08/2009

General Page: 1

Of: 2

Throughout all processing at Sandvik Materials Technology material identification shall be accomplished in such manner that any material can be traced to work order and heat origin at any point in the processing.

5

Test material for final acceptance testing and examination is identified by tagging the material or identifying the sample container with (as a minimum) the work order and/or lot number by the individual assigned that duty by approved Control Procedure and Instruction or instructions on the work order. The identification is verified by inspectors or laboratory personnel.

10

If material or product is suspected to be nonconforming to applicable requirements anytime during the processing, a yellow hold tag (EXHIBIT 7), reject tag (EXHIBIT 5), or uniquely numbered Nonconforming Material Report (NCMR) (EXHIBIT 17) shall be applied to the suspect material by the inspector. Removal of tags shall be by the inspector.

15

When material or product is found to be nonconforming, the material or product is labeled by inspectors with the reject

tag (EXHIBIT 5) or the uniquely numbered NCMR (EXHIBIT 17). All

material bearing reject tags or NCMRs shall be segregated by the inspector. Material is not processed until material disposition is received from the Quality Assurance Department, per Section 8.5, "Control of Nonconforming Material" of this Manual. 20 When there are several units included on a rejection tag, such as several skids of material, a red rejection tag (EXHIBIT 5) or the uniquely numbered NCMR (EXHIBIT 17) will be attached by the inspector to each individual unit. When the reject tag is used, it shall be marked with the unique NonConforming Material Report number.

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

IDENTIFICATION, MARKING, AND MATERIAL CONTROL

Section: 6.1 Issue: 3 Revision: 0 Date: 04/08/2009

General Page: 2

Of: 2

Identification and control are performed by utilizing a work order system and shop travelers. All material is identified by tagging with work order number during all steps of manufacturing. The work order number is traceable to the heat number, grade and size of material or description of product. Material assigned to each work order must be from one heat and must be of the same starting size. 5

Each work order must be for one final size and for the same material or product specification.

The shop travelers (EXHIBITS 8 and 9) list each operating step in sequence.

Listed also are

applicable material specifications and Control Procedures and Instructions to be used during operations. The indication of the revision level for Control Procedures and Instructions on the traveler 10

is not required. All operations shall be completed to the latest revision of the referenced Control Procedures and Instructions as controlled in the Section 3.3 of this manual. After completion of each manufacturing step for tubular products and welding products (set-up steps are excluded), the operator signs and dates the traveler, and after completion of each inspection step, the traveler is signed off and dated by the inspector. Completion of testing steps is signed off by the operator or

15

inspector as appropriate for the test performed for tubular products, and by the inspector for welding products. Each work order is represented by one traveler, which accompanies the material during all processing steps.

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

IDENTIFICATION, MARKING, AND MATERIAL CONTROL

Section: 6.2.1 Issue: 3 Revision: 0 Date: 04/08/2009

Marking Methods and Identification of Completed Material - Tube Page: 1

Of: 3

Identification and control of incoming source material in the form of tube hollows is accomplished through the use of legible tags or linemarking containing the grade, size, heat number, and lot number, at a minimum. The absence of legible identification shall result in the scrapping of the material. 5

After receiving verification per Section 5, "Control of Purchased Materials, Source

Materials, and Services" of this Manual, material can be assigned for production.

Identification and control of material during production is accomplished through the use of heat number and work order number. This control is established from the time raw material is assigned to a work order until the shipment of finished product from production or inventory. 10 Processing and handling of pipe and tube during manufacturing is done in the form of bundles. Each bundle is identified by two Bundle Identification Tags (EXHIBIT 10), showing the work order number. The work order traveler will indicate the starting number of pieces.

15

The bundle identification tags are attached to each bundle by operators when source material, in the form of hollows, is assigned to a work order of pipe and tube.

It is the responsibility of operators and/or inspectors, as applicable, to attach one tag to the first piece going through any given operation or testing step, or to the container where the accepted pieces are 20

being collected, and to attach the second tag to the bundle immediately after the last piece is processed. During processing, the second tag shall remain at a designated spot at the process station.

The second tag will note the amount of pieces processed at the following steps: hydrostatic testing, 25

nondestructive testing when line marking is not combined with this test, and final inspection.

At any operation resulting in an intentional change of the number of pieces (such as cutting) the number of pieces shall be determined and recorded on the bundle identification tag by the operator.

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

IDENTIFICATION, MARKING, AND MATERIAL CONTROL

Section: 6.2.1 Issue: 3 Revision: 0 Date: 04/08/2009

Marking Methods and Identification of Completed Material - Tube Page: 2

Of: 3

The piece count from the bundles for each work order shall be summarized on the traveler for each of the above mentioned operational steps.

For a given work order, the number of pieces rejected or scrapped, if any, at an operational step, 5

shall be summarized and recorded on the traveler.

If a discrepancy has occurred in the piece count, Quality Assurance shall be notified immediately to investigate and resolve the discrepancy. The work order shall go on hold (hold tags applied), and will be released only by Quality Assurance when the discrepancy is satisfactorily resolved. 10 The in-process identification system and the use and control of the bundle identification tag is detailed in an approved Control Procedure and Instruction.

As a final check that all processing steps have been performed in accordance with the work order, 15

each traveler is given a final review by inspectors at the completion of final inspection. This review is a part of final inspection and is recorded by inspectors on the final inspection form (EXHIBIT 11) and by inspectors signing and dating the traveler opposite the final inspection step.

Final marking of pipe and tube is performed in accordance with applicable specifications and with (as 20

a minimum) the following information: Sandvik's identification mark, work order number, grade, heat number, size and specification. The heat number and the work order number identify the material with the material certification.

The method of marking, normally performed as continuous line

marking, shall not result in harmful contamination or sharp discontinuities.

25

The flow diagram on the following page shows the identification system applied to pipe and tube manufacturing.

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

Section: 6.2.1 Issue: 3 Revision: 0 Date: 04/08/2009

IDENTIFICATION, MARKING, AND MATERIAL CONTROL Marking Methods and Identification of Completed Material - Tube

Page: 3

Source Material (Hollows)

Identification of Pipe and Tube 1. Each length stenciled with heat, size, and grade.

1

Receiving Verification Inventory Stock

Of: 3

2

1

Segregated Areas

3

2. Reject tag listing, heat, size, grade, number of pieces, quantity rejected, reason for rejection, and reject (NCMR) number. 3. Bundle identification tag listing work order number. Work order number is traceable to travel card. 4. Linemarking with heat, size, grade, work order number, and specification.

Manufacturing

5. Material tagged with heat, size, grade, work order number and specification. 6. Tape showing linemarking sent with inspection report to Quality Assurance

3

Linemarking

Note: Hold tag with work order number any time during processing when discrepancy found in piece count.

3,4 2

Inspection

3,4

Packaging Inspection Q.A. Approval

6

Quality Assurance

4, 5

Inventory Stock or Shipping

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

IDENTIFICATION, MARKING, AND MATERIAL CONTROL

Section: 6.2.2 Issue: 3 Revision: 0 Date: 04/08/2009

Marking Method and Identification of Completed Products - Wire Page: 1

Of: 6

General Identification of material is established through the use of travelers (EXHIBIT 9), work-in-process cards or material identification tags (EXHIBIT 12), green "OK TO PROCESS" tags (EXHIBIT 13), and yellow hold tags (EXHIBIT 7). 5 Identification and control of material for bare electrodes, rods, and wire products is accomplished through the use of heat number and work order number. This control is established from the time that source material is assigned to a work order until shipment of finished product. When it is established through the receiving verification per Section 5, "Control of Purchased Materials, Sources 10

Materials and Services" of this Manual that the material, hot-rolled rod or cold drawn wire, conforms to the procurement order requirements, and the material has been released by the Product Area Quality Professional following receiving verification, Production may apply the material to the work order. Material will be located and held in storage until applied to work orders for processing.

15

Hot Rolled Rod and Cold Drawn Wire Hot rolled rod to be drawn to wire by Sandvik Materials Technology will be examined by Sandvik personnel and verified against work order for correctness when removed from inventory by the material handler and again by the operator when the rod is conditioned. The durable identification tags placed on the hot rolled rod by the supplier of materials contain purchase order number, heat

20

number and material specification or grade. The tags will remain with the material until the first drawing operation. The inspector will verify the correctness of the material identity, including size, grade and quantity and the collection of the correct number of test samples for each work order for alloy identity testing. See Section 7, "Process Control" of this Manual.

25

At this stage, the material will be identified by a work-in-process card or material identification tags (EXHIBIT 12). The inspector verifies and documents that all requirements have been met by initially and dating the traveler. The material is tagged with an “OK TO PROCESS” tag (EXHIBIT 13) by the operator and moved for further processing.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

IDENTIFICATION, MARKING, AND MATERIAL CONTROL

Section: 6.2.2 Issue: 3 Revision: 0 Date: 04/08/2009

Marking Method and Identification of Completed Products - Wire Page: 2

Of: 6

Wire being further processed through the drawing, annealing and cleaning operations will, at each stage during processing, be identified with work-in-process cards or material identification tags.

5

Splicing by welding may be done between wire coils from the same work order (i.e., the same heat and size of material) when allowed by the applicable material specification. An alloy identity test per Section 8, "Control of Examinations, Tests, and Nonconforming Material" of this Manual shall be performed for welding material on each end to be spliced in accordance with established Control Procedure and Instruction, except where material is spliced to repair a break during manufacturing.

10

The alloy identity test is documented on the traveler (EXHIBIT 9) or the in-process/final inspection form (EXHIBIT 21) by the inspector.

Splicing by welding is done between work orders when the splice can be positively identified by crimping or coloring by the operator. The splice shall be removed after the processing operation. 15

Removal of the splice shall be verified by the inspector who signs and dates the traveler. In-process inspection of the removal of the splice may take place in parallel with subsequent operations as described in the traveler.

If the processing is the drawing operation, confirmation of weld removal will be done as established in 20

Control Procedure and Instruction for alloy identity testing.

See Section 8.1.2, "Inspection,

Examination, and Test Control - Testing", of this Manual.

The following flow diagram shows the identification system during processing of hot rolled rod to cold drawn wire

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PRODUCT AREA TUBE

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IDENTIFICATION, MARKING, AND MATERIAL CONTROL

Section: 6.2.2 Issue: 3 Revision: 0 Date: 04/08/2009

Marking Method and Identification of Completed Products - Wire Page: 3

Of: 6

Identification of Hot Rolled Rod and Sandvik Cold Drawn Wire

Source Material (Hot Rolled Rod/Inventory Stock)

1. Supplier marking label or tag with: heat, purchase order number, and grade or material specification. 2. Work-in-progress card or ID tag with (as a minimum) work order number.

1, 2

Identity Verification Conditioning

3. Hold tag with (as a minimum) work order number. 4. OK-to-Process tag with (as a minimum) work order number. 5. Reject tag with: heat, grade, size, reject number, work order number, weight and quantity.

1, 2 2, 4

Drawing

In-Process Inspection

6. ID tag for final identification with: heat, grade, size, and work order number. 7. Coil or spool label with: heat, grade, size, work order number, and specification.

2, 3

2,4

Annealing Drawing Cleaning

3,4

Hold

2

Inspection Q.A. Approval

6

Immediate Inventory Stock

8. Sample labels sent with inspection report to Quality Assurance.

5 5

Segregated Area

7, 8

Inventory Stocking or Shipping

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Section: 6.2.2 Issue: 3 Revision: 0 Date: 04/08/2009

IDENTIFICATION, MARKING, AND MATERIAL CONTROL Marking Method and Identification of Completed Products - Wire

Page: 4

Of: 6

Bare Electrodes and Rods Cold drawn wire to be processed to bare welding electrodes and welding rods is given an incoming inspection by the inspector to verify identity prior to processing and to confirm that the wire conforms to the work order requirements. Green "OK TO PROCESS" tags (EXHIBIT 13) containing the work 5

order number, are affixed to the material by the inspector.

The identification tags placed on the cold drawn wire by Sandvik or the supplier of materials are examined by inspectors along with the material at incoming inspection and remain on the wire and follow it right up to the time the wire is placed on the processing machine, at which time the tags are 10

disposed of by the operators.

As the material is processed, further identification tags and labels are applied to the material by operators. In the case of cut straight length rods, the material is placed into containers having identification labels attached by the operators. In the case of spooled electrodes, labels with the 15

appropriate information are placed by the operators on the spools as they are moved from the spooling machines.

These identification labels remain on the spools and are not removed by

Sandvik.

The final identity of material is accomplished by final labeling of the material by operators when all 20

processing is completed.

The final labeling is performed in accordance with applicable material specifications listed on the traveler, and with (as a minimum) the following information: Sandvik's identification name, grade, heat, size, work order number, specification and weight. 25

The heat number and the work order

number or lot number identify the material with certification.

The inspector verifies by signing and dating the traveler that the material receives the proper identification at the final labeling stage. He also verifies that the traveler operation has been signed off. When the inspector is satisfied that the material is acceptable and the labels contain the proper

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PRODUCT AREA TUBE

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IDENTIFICATION, MARKING, AND MATERIAL CONTROL

Section: 6.2.2 Issue: 3 Revision: 0 Date: 04/08/2009

Marking Method and Identification of Completed Products - Wire Page: 5

Of: 6

information, he signs off and dates and attaches to the traveler and forwards to Quality Assurance one copy of the final labels for each work order.

The flow diagram on the following page shows the application of identification tags during processing 5

of bare electrodes and rods.

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Section: 6.2.2 Issue: 3 Revision: 0 Date: 04/08/2009

IDENTIFICATION, MARKING, AND MATERIAL CONTROL Marking Method and Identification of Completed Products - Wire

Page: 6

Source Material (Cold Draw n Wire or Inventory Stock)

Identification of Bare Welding Electrodes

Sandvik Cold Draw n Wire Inter mediate Inventory Stock

1

1. Supplier marking label or stamp rods with heat, lot number, and grade or material specification. 2. OK-to-Process and ID tag with (as a minimum) work order number. 3. Reject tag with heat, grade, size, reject number, work order number. 4. Spool label with heat, grade, size, work order number, and specification. 5. Box label with heat, grade, size, work order number. 6. Rods individually stamped with heat number and grade. 7. Hold tag with (as a minimum) work order number. 8. Sample labels sent with inspection report to Quality Assurance. 9. Box or tube labels for bare electrodes and rods with heat, grade, size, work order number, specification, and weight. 10. ID tag with heat, grade, size, work order number from wire drawing operation.

10

Incoming Inspection or Identity Verification

3

Segregated Area

2

2

Electrode Spooling

Rod Cutting

5

4

5,6

5

Stamping Tagging 3

In-Process Inspection

7,2

Packing Final Inspection Q.A. Approval 9

3

Hold

4,5,6

5 8

Of: 6

Quality Assurance

Inventory Stocking or Shipping

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PROCESS CONTROL

Section: 7.1.1 Issue: 3 Revision: 0 Date: 04/08/2009

General Page: 1

Of: 1

The manufacturing of pipes, tubes, bare electrodes, rods, and wire is performed under a controlled system, utilizing Operating Directives and Instructions, work orders and travelers, as well as approved Control Procedures and Instructions for control of special processes, examinations and tests. The controlled system utilizes the work orders and travelers (EXHIBITS 8 and 9) to assure that all processes and production steps are controlled in accordance with applicable material and customer specifications and the rules of ASME Code Section III.

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* * * PRODUCT AREA WIRE

PROCESS CONTROL

Section: 7.1.2 Issue: 3 Revision: 0 Date: 04/08/2009

Special Processes Page: 1

Of: 2

Special processes are those of which the process result cannot be fully verified by subsequent inspection, testing, and examination of the material or product. They shall be qualified and carried out under controlled conditions per Section 7.1.1, "Process Control, General" of this Manual.

5

Heat treating and nondestructive examination are special processes used by Sandvik.

Heat treating is a requirement for tubular products and welding products, based on standard material and product specifications as well as special customer requirements.

10

Nondestructive examination is used for tubular products (ultrasonic testing and eddy current testing) and for welding products (radiography).

Heat treating and nondestructive examination of tubular products are controlled by Control Procedures and Instructions, approved by the Director/Manager, Quality and Metallurgy, and by 15

specific instructions given on travelers, and are performed by personnel who are trained and qualified per applicable internal requirements or per applicable Code and specification requirements in accordance with Section 2.1, “Indoctrination, Training, and Qualification of Personnel” of this Manual.

Heat treating of pipe and tube is performed in continuous-type furnaces per a Control Procedure and 20

Instruction referenced on the traveler. The qualification of the furnace shall be done by performing furnace uniformity test per a Control Procedure and Instruction. Heat treat data in the form of time, temperature, travel speed, date, pieces per load and operator are recorded by the furnace operator on the traveler. Inspectors verify that the operation was performed by reviewing and signing and dating the traveler at final inspection. Time-temperature furnace charts showing time, temperature

25

and date are filed by the Product Area Quality Professional, the Quality Technician, or the Materials Analyst.

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Section: 7.1.2 Issue: 3 Revision: 0 Date: 04/08/2009

PROCESS CONTROL Special Processes

Page: 2

Of: 2

Thermocouples are calibrated per Section 8.2, "Control of Measuring and Test Equipment" of this Manual, and calibration records are verified and filed by the Quality Assurance.

Nondestructive examination operations of tubular products shall be performed in accordance with 5

Control Procedures and Instructions, approved by the authorized Level III person, and shall be listed on the traveler and shall be available to the examiner.

Procedures shall be proven by actual

demonstration to the satisfaction of the Level III person. This is documented by the Level III person approving the procedures. Nondestructive examination procedures shall be distributed per Section 3.3, "Document Control" of this Manual. Control of nondestructive examinations are further explained 10

in Section 8.1, "Inspection, Examination and Test Control" of this Manual.

Nondestructive examination of welding products (radiography) is performed by supplier of outside services.

15

The Approved Suppliers List for ASME Section III and Military Applications includes independent laboratories which perform special processes. All laboratories on the Approved Suppliers List are audited for adequacy of their Quality System and their capability per Section 5, "Control of Purchased Materials, Source Materials, and Services".

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PROCESS CONTROL

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Date: 04/08/2009

Page: 1

Of: 6

Manufacturing Process Control

Work orders are prepared and issued by Product Area Production Control to Production to cover the manufacturing of tubular products and welding products. Work orders for Code material and their revisions are reviewed and approved by Product Area Quality Professional or designee to assure proper requirements are transferred from the Customer Order. The work order will detail material 5

grade, size, heat number, lot number, method and sequence of manufacture and any special production, inspection, testing, and examination requirements per the Customer Order, Code, or applicable level for non-Code Work.

Material assigned to a work order shall be only material accepted per Section 5, “Control of 10

Purchased Materials, Source Materials, and Services” of this Manual.

Production Control identifies on the work order the specific lot number and heat number of the source material to be used, and Product Area Quality Professional or designee reviews the work order for tubular products and welding and wire products for ASME Code III material prior to issuance to verify 15

the acceptability of the material as indicated. This acceptance is based on the following: (1) Material applied meets the requirements of the material specification, Code and customer order; (2) All procedures to meet the material specification and customer order are correct, accurate and in the correct sequence; (3) That no violation of Code procedures are noted on the work order. When the Product Area Quality Professional /QualityTechnician approves the work order, he/she will sign and

20

date the same.

The work order set may includes several copies identical with EXHIBITS 8 and 9. The primary copy is used as the traveler copy.

Other copies may be used by Inspection, Production Control,

Warehouse, Quality Assurance, or Production as needed. 25 Rework of material or products during manufacturing is limited to allowances in applicable material or product specifications and customer orders. When rework is performed after testing or inspection activities, the reworked material or product shall be re-tested or re-inspected, as applicable, per the

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PROCESS CONTROL

Section: 7.2 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 2

Of: 6

Manufacturing Process Control

same acceptance criteria used for the initial testing or inspection. Rework or repair by welding shall not be performed on any tubular products and welding material.

When deemed meaningful and when required by customer orders, process control plans and 5

statistical process control methods shall be developed and implemented and used for monitoring of certain products or processes as specified in applicable Control Procedures and Instructions or Operating Directives and Instructions.

Criteria for workmanship, when practical, is defined in applicable Control Procedures and 10

Instructions, in Operating Directives and Instructions, or by means of representative samples.

Material and products which are found to be nonconforming after rework, re-testing and re-inspection shall be handled per Section 8.5, "Control of Nonconforming Material" per this Manual.

15

The following pages show detailed manufacturing and quality control flow diagrams for the flow of material or product from the receiving stage to final release and shipping.

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PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

PROCESS CONTROL

Section: 7.2 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 3

Of: 6

Manufacturing Process Control

9.1.1

Detailed Manufacturing and Quality Control Flow Diagram for Pipe and Tube

All reworked material is re-tested and re-inspected. All nonconforming material is rejected.

Source Material Receiving Verification

Material Receiving Verification

Q.A. Approval Inventory Stock Q.A. Work Order Review and Material Verif ication

Q.A. Approval

Incoming Inspection Manufacturing Linemarking

Inventory Stock

Testing Examination Inspection

Customer Order Processing

Packaging Inspection Q.A. Approval Certification

Shipping

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

PROCESS CONTROL

* * * PRODUCT AREA WIRE

Section: 7.2 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 4

Of: 6

Manufacturing Process Control

9.1.2

Detailed Manufacturing and Quality Control Flow Diagram for Cold Drawing of Wire from Hot Rolled Rod

All reworked material is re-tested and re-inspected. All nonconforming material is rejected. Source Material Hot Rolled Rod Receiving Verif ication

Q.A. Approval Inventory Stock Q.A. Work Order Review and Material Verif ication

Conditioning

Drawing

Hold Q.A. Release Annealing Drawing Cleaning

In-Process Inspection

Inspection Q.A. Approval

Quality Assurance Certification

Intermediate Inventory Stock

Shipping

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

PROCESS CONTROL

Section: 7.2 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 5

Of: 6

Manufacturing Process Control

9.1.3

Detailed Manufacturing and Quality Control Flow Diagram for Bare Welding Electrodes and Rods

All reworked material is re-tested and re-inspected. All nonconforming material is rejected. Source Material Cold Draw n Wire Receiving Verif ication Q.A. Approval

Sandvik Cold Draw n Wire

Inventory Stock Incoming Inspection or Identity Verif ication

Cutting

Spooling, Cleaning Labelling

Cleaning

Bare Wire Identification Tagging

In-Process Inspection Packaging/ Labelling

Testing

Final Inspection Q.A. Approval

Q.A. Certification

Shipping

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* * * PRODUCT AREA WIRE

PROCESS CONTROL

Section: 7.2 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 6

Of: 6

Manufacturing Process Control

9.1.4

Detailed Manufacturing and Quality Control Flow Diagram for Strip Electrodes, Fluxes and Other Types of Welding Materials, Manufactured by Outside Vendors

Material Receiving Verification

Marking and Labelling

Q.A. Approval

Packaging

Inventory Stock

Inspection

Customer Order Processing

Testing

Inspection Q.A. Approval

Q.A. Certification

Shipping

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

Section: 7.4 Issue: 3 Revision: 0 Date: 04/08/2009

Process Control Handling, Storage, Shipping, and Preservation

Page: 1

Of: 1

Sandvik makes every effort to maintain high levels of cleanliness in its manufacturing and warehouse operations through good housekeeping, which is encouraged by Sandvik management.

5

The procedures for handling, protection and storage of materials and products to prevent damage and deterioration as well as procedures for packing, marking and shipping, are written in the form of Control Procedures and Instructions as required. They regulate, in detail, the special procedures to be followed by Production and Quality Assurance personnel, as well as special requirements regulated by specific customer requirements.

10

When special procedures are

required, they are specified on the traveler and verified by inspector signature and date.

Standard practices meeting ANSI, ASME, ASTM, AWS, MIL and other specifications are used for packing of tubular product and welding and wire products.

When additional customer

requirements apply, they shall be indicated in the work order. 15 Handling, protection and storage is performed to minimize contamination of pipe and tubes after final cleaning. Clean slings are used for carrying tube bundles with overhead cranes; plastic sheets are also used as lining in shipping containers when so specified. When specified by the customer, plastic end caps are used on each length of pipe and tube.

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE * * * PRODUCT AREA WIRE

CONTROL OF EXAMINATIONS, TESTS, AND NONCONFORMING MATERIAL

Section: 8.1.1 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 1

Of: 4

Inspection, Examination, and Test Control - Inspection

The overall inspection system for material and product examination utilizes Control Procedures and Instructions and is designed in order to comply with requirements per ASME Code Section III, ASME, ASTM, AWS and other specifications, as well as requirements as specified in customer orders. 5 Inspection shall be performed by personnel trained and qualified in accordance with Section 2, "Personnel", of this Manual and per approved Control Procedures and Instructions. Tubular products and welding products per ASME Code Section III shall be inspected by qualified inspectors. Personnel performing inspection shall be other than those who have performed the 10

activity being inspected and shall not report directly to the immediate supervisor responsible for the work being performed.

Control of purchased material and product is accomplished by receiving verification activities in accordance with approved Control Procedures and Instructions applicable to each Product Area. 15 The receiving verification includes verification of packing list to be in accordance with purchase order and verification of material to be in accordance with packing list. When applicable, the material verification includes product marking and identification. The verifications are documented by responsible personnel by signing and dating applicable documents or by 20

controlled entry and exit when electronic storage of data and records is used.

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CONTROL OF EXAMINATIONS, TESTS, AND NONCONFORMING MATERIAL

Section: 8.1.1 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 2

Of: 4

Inspection, Examination, and Test Control - Inspection

Certified Material Test Reports for tubular products and welding products are reviewed and approved by the Product Area Quality Professional or designee. When electronic storage of data and records is used for Certified Material Test Reports and Material Certificates, controls shall be specified in an approved Control Procedure and Instruction. 5 All suppliers of source material, material and services are required to supply material certificates with the material. Material organizations having an ASME Quality System Certificate (Materials) shall certify that the material or service was produced under the provision of ASME Code and include their Quality System certificate number and expiration date. Suppliers of source material 10

and subcontracted services and material organizations not having an ASME Quality System Certificate which have been approved by the Director/Manager, Quality and Metallurgy shall list the revision and date of the written program to which the source material, material, or service was manufactured or supplied. It shall be the responsibility of Quality Assurance to verify that the required information is correct. The Approved Supplier Listing for ASME Section III and Military

15

Applications shall be used as the principal reference document.

No material received is placed in allocatable inventory or applied to a work order or customer order until receiving verification is completed and documented. All inventoried material shall be identified and traceable to the procurement documents by heat number and purchase order 20

number/lot number.

Any material not conforming to the requirements per purchase order and material specifications, will be rejected and so identified. It will be segregated to await Product Area Quality Professional disposition in accordance with the nonconforming material handling procedure per Section 8.5, 25

"Control of Nonconforming Material", of this Manual.

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CONTROL OF EXAMINATIONS, TESTS, AND NONCONFORMING MATERIAL

Section: 8.1.1 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 3

Of: 4

Inspection, Examination, and Test Control - Inspection

The identification of source material or material assigned to a work order shall be verified by trained and qualified personnel per applicable approved Control Procedure and Instruction, Process Outline, or Process Control Plan/Quality Control Plan.

5

When incoming inspection is required, it is performed by inspectors per approved Control Procedures and Instructions referenced on the traveler.

In-process inspection of welding products and final inspection of pipe and tube and welding products are performed by inspectors per approved Control Procedures and Instructions to verify 10

that material meets material specification and Code requirements.

Sampling of pipe and tube is done per MIL-STD-105E and ANSI Z1.4.

Sampling of semi-finished and finished material for bare electrodes, rods and welding inserts is 15

done per Specification MIL-E-19933 for stainless grades and MIL-E-21562 for nickel alloys, copper-nickel and copper alloys.

Sampling and AQL is established in approved Control Procedures and Instructions.

20

Detection of a defect at inspection by sampling for Code material shall require the total inspection of that lot of material for that attribute.

Acceptance of covered electrodes per Code requirements is based on inspection by Quality Assurance per approved Control Procedure and Instruction. 25

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CONTROL OF EXAMINATIONS, TESTS, AND NONCONFORMING MATERIAL

Section: 8.1.1 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 4

Of: 4

Inspection, Examination, and Test Control - Inspection

Customer inspection hold points are not normally used in the manufacturing process. However, upon request from a customer, such hold points could be established for the purpose of customer review and observation of final inspection and testing operations.

5

If material or products, at any stage in the process of manufacturing or during examination and testing, is found to be nonconforming, and not capable to be re-worked, the material or product will be handled in accordance with Section 8.5, "Control of Nonconforming Material", of this Manual.

10

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* * * PRODUCT AREA WIRE

CONTROL OF EXAMINATIONS, TESTS, AND NONCONFORMING MATERIAL

Section: 8.1.2 Issue: 3 Revision: 1

Date: 04/08/2009

Page: 1

Of: 4

Inspection, Examination, and Test Control - Testing

General All testing is done in accordance with approved Control Procedures and Instructions, Laboratory Procedures and Instructions, and customer requirements. The Product Area Quality Professional or Materials Laboratory personnel review test procedures and documents and verify by signing 5

and dating that all test results meet the applicable requirements. No material or products will receive final approval and certification from the Quality Assurance Department unless the required tests are performed and the results are documented and verified to be within acceptable limits.

10

Test samples are identified as a minimum by work order or lot number, which is traceable to specification, size and heat number.

Identification is done by the individual responsible for

collecting samples and is maintained by laboratory personnel.

Destructive testing such as physical testing and corrosion testing is performed by Materials 15

Analysts in Sandvik's Materials Laboratory in accordance with applicable specifications and customer requirements. Test material is identified, at a minimum, by work order number, which is traceable to specification, size and heat number. Identification is verified by laboratory personnel when collecting samples and is maintained by laboratory personnel during testing.

20

Nondestructive examinations are performed by Sandvik or by an approved supplier of testing services.

Approved procedures, which assure compliance with ASME Code Section III,

applicable material specifications and customer requirements, are issued and maintained on a controlled copy basis by the Quality Assurance Department, along with applicable personnel qualifications. 25 The Sandvik Level III person prepares the written practice in the form of a Control Procedure and Instruction, which shall comply with the applicable edition of SNT-TC-1A. For material per ASME Code Section III requirements, the written practice shall comply with SNT-TC-1A (edition as G:\Quality Assurance\Controlled Documents\ASME Manual\Issue 3 Revision 0\8-1-2 Issue 3 Rev 0.DOC

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CONTROL OF EXAMINATIONS, TESTS, AND NONCONFORMING MATERIAL

Section: 8.1.2 Issue: 3 Revision: 1

Date: 04/08/2009

Page: 2

Of: 4

Inspection, Examination, and Test Control - Testing

specified in the Code) and the Code. The written practice is approved by the Director/Manager, Quality and Metallurgy. When nondestructive examination is performed by an approved supplier of services in accordance with the ASME Code, the following shall apply: 5

(1) The suppliers written practice shall be reviewed and approved by the Director/Manager, Quality and Metallurgy as complying with SNT-TC-1A (edition as specified in the Code) and the Code; (2) The supplier personnel qualification records are reviewed and approved by the Director/Manager, Quality and Metallurgy or Level III person;

10

(3) The nondestructive examination procedures to be used by the supplier shall be the Sandvik Control Procedure and Instruction or the supplier's procedure approved by the Director/Manager, Quality and Metallurgy, or Sandvik Level III.

The nondestructive

examination procedure shall be specified on the purchase order; (4) Supplier's nondestructive examination report shall be reviewed and approved by the Product 15

Area Quality Professional. At a minimum, these nondestructive reports shall indicate the applicable examination procedure, the name and qualification level of the individual performing the examination, reference to Sandvik purchase order/work order, number of pieces examined, and number of pieces accepted.

20

Pipe and Tube Testing is scheduled in the production operation sequence. Testing is performed to assure compliance with applicable materials specifications, ASME Code Section III, and customer requirements. These requirements are specified on Product Requirement Review Sheet listed on the traveler. Detailed Control Procedures and Instructions for testing are listed on the traveler and

25

are available at each test station and maintained on a controlled copy basis by Quality Assurance. They are available for review and approval by customers upon request.

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CONTROL OF EXAMINATIONS, TESTS, AND NONCONFORMING MATERIAL

Section: 8.1.2 Issue: 3 Revision: 1

Date: 04/08/2009

Page: 3

Of: 4

Inspection, Examination, and Test Control - Testing

Welding Materials Testing is performed to assure compliance with applicable materials specifications, ASME Code Section III, MIL, and customer requirements.

These requirements are specified on Product

Requirement Review Sheet listed on the traveler. 5

Tests performed by Sandvik on welding

materials are chemical analysis, ferrite determinations, all-weld metal tensile tests, fillet weld tests, groove weld usability tests and bend tests.

Test welding is performed in the Welding Laboratory by the test welder and the Materials Laboratory personnel perform the chemical analysis and physical testing as specified on the 10

specification review sheet.

Radiography testing of weld plates per MIL specifications, customer or Code requirements is performed by an approved outside testing laboratory.

15

In order to meet the requirements of certain MIL Specifications for welding materials, weld metal material for MIL and Code applications is subjected to alloy identity testing during incoming inspection. This alloy identity testing is performed by inspectors and/or Materials Laboratory on each coil of hot rod and each coil, and capstan or spool of cold drawn. It involves the use of an optical emission spectrometer or chemical analysis or other approved methods as specified in

20

approved Control Procedure and Instruction for alloy identity testing. Alloy identity testing is documented by the inspector signature and date on the traveler.

Such controls of welding materials identity for MIL and Code applications are also applied at the time of splicing by welding during further processing by Sandvik Materials Technology or its 25

vendor.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

CONTROL OF EXAMINATIONS, TESTS, AND NONCONFORMING MATERIAL

Section: 8.1.2 Issue: 3 Revision: 1

Date: 04/08/2009

Page: 4

Of: 4

Inspection, Examination, and Test Control - Testing

Welding Products Testing is performed to assure compliance with applicable materials specifications and customer requirements.

Chemical analysis and mechanical testing is performed by the Materials

Laboratory. 5

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

Section: 8.2 Issue: 3 CONTROL OF EXAMINATIONS, TEST, AND NONCONFORMING MATERIAL Revision: 0 Control of Measuring and Test Equipment Page: 1

Date: 04/08/2009 Of: 3

Measuring and test equipment must be calibrated, used and properly maintained to assure accuracy within necessary limits.

The calibration program is documented in a Control Procedure and Instruction. The program, 5

based on MIL-STD-45662A and ISO 10012, provides for the control of the accuracy of the measuring and test equipment which is used to assure that supplies and services presented to the government or a customer representative for acceptance, are in conformance with prescribed technical requirements.

10

Calibration is performed by the Quality and Metallurgy Function or by a qualified subcontractor of calibration services.

New and repaired measuring and test equipment is calibrated and/or verified prior to use. Master gauge blocks used for calibration and instruments to be calibrated will be kept at the same 15

maintained temperature (+/-5oF) before and during calibration to eliminate any deviation due to temperature change.

All measuring and test equipment shall be identified, serialized and a calibration record file maintained by the Quality and Metallurgy Function. All measuring and test equipment records 20

shall identify the equipment and show the frequency of calibration requirements, tolerances, results, procedure and revision used, traceability to the standard used, the name of the person performing the calibration, and the date of calibration. Where appropriate, steps shall be taken to prevent possible adjustments to measuring equipment that would invalidate the calibration and subsequent measurement results. This may include, but is not limited to, removing wrenches

25

from the storage boxes and sealing adjustment screws with wax.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

Section: 8.2 Issue: 3 CONTROL OF EXAMINATIONS, TEST, AND NONCONFORMING MATERIAL Revision: 0 Control of Measuring and Test Equipment Page: 2

Date: 04/08/2009 Of: 3

Records may consist of electronically-maintained records (See Section 3.4 For Computer Security) or certifications from suppliers of calibration services.

The boxes or receptacles where the instruments and gauges are stored shall be properly 5

identified with the identification traceable to the instruments, and any defective and obsolete gauges shall be immediately withdrawn from use and records shall be noted accordingly. Calibration stickers are used to indicate date of calibration and next calibration due date and the initials of the person performing the calibration.

10

All measuring and test equipment shall be calibrated utilizing reference standards whose calibration is certified as being traceable to national standards, where such standards exist, or the equipment manufacturer's recommended standards.

Reference standards requiring

calibration by a high level standards laboratory shall be calibrated by an approved commercial facility capable of providing the required service, a government laboratory or by the National 15

Institute of Standards and Technology (NIST). All reference standards used in the calibration system shall be supported by certificates, reports, instrumentation identification and data sheets attesting to the date, accuracy and conditions under which the results furnished were obtained.

The calibration source (Quality and Metallurgy Function or subcontractor) shall notify the 20

responsible Product Area Quality Professional in writing of measuring and test equipment found to be out-of-tolerance. Measuring and test equipment damaged is considered out-of-tolerance.

When periodic checks to determine that calibration is maintained are performed by someone other than the Quality and Metallurgy Function, necessary adjustments and re-calibration, as 25

deemed necessary, shall be performed by the Quality and Metallurgy Function.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

Section: 8.2 Issue: 3 CONTROL OF EXAMINATIONS, TEST, AND NONCONFORMING MATERIAL Revision: 0 Control of Measuring and Test Equipment Page: 3

Date: 04/08/2009 Of: 3

Equipment for mechanical testing, such as tensile testing machines, hardness testers, equipment for temperature control, pressure gauges, are calibrated at the established intervals by an approved outside supplier of calibration services.

5

Calibration records will include the certification of equipment from the supplier with the results of their test referenced in Sandvik's gauge records. The certification shall be checked by Quality and Metallurgy Function personnel to verify that the certification is signed and dated and that the equipment is within the specified tolerances as stated on the gauge record card. When it is determined that the certification is in compliance with the above, gauge records will be updated

10

accordingly.

Standard nondestructive examination equipment is calibrated per approved Control Procedure and Instruction, and calibration records and controls shall be in accordance with this section of the Manual. 15 For chemical analysis equipment calibration is performed and maintained by Materials Laboratory personnel.

Calibration records for this kind of equipment is maintained and stored by the

Materials Laboratory personnel and shall be traceable to the equipment serial number.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

Section: 8.3 Issue: 3 CONTROL OF EXAMINATIONS, TEST, AND NONCONFORMING MATERIAL Revision: 0 Discrepancies in Measuring and Test Equipment Page: 1

Date: 04/08/2009 Of: 1

The Product Area Quality Professional shall document what corrective action is required for the material or products which the defective measuring and test equipment could have been used on since the last valid calibration of the measuring and test equipment. Since Sandvik does not use specific measuring and test equipment, all material or product of the size, condition, or process 5

applicable to the use of the measuring and test equipment is considered suspect. If a review determines that all applicable material or product requirements have not been met, the Product Area Quality Professional shall prepare a Nonconforming Material Report identifying the involved material or product by work order number and heat number. The Nonconforming Material Report shall be processed in accordance with Section 8.5, "Control of Nonconforming Material" of this

10

Manual. When nonconforming material already has been shipped, the customer shall be notified in writing of the condition.

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

CONTROL OF EXAMINATIONS, TESTS, AND NONCONFORMING MATERIAL

Section: 8.4 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 1

Of: 1

Inspection and Test Status

Throughout the entire manufacturing operation sequence, the inspection and test status is identified by a series of recording and labeling activities.

The system is designed to ensure that no material or product is dispatched until all the specified 5

inspection and testing activities have been satisfactorily completed and the associated data and documentation have been reviewed and approved by authorized personnel.

Verification of compliance to customer orders, work orders and Product Requirements Review Sheets is accomplished prior to shipping or stocking, and when the material or product is ready to 10

be certified. At the time of certification, Quality Assurance is responsible for having compiled all required information to assure that the detailed requirements are met. This is accomplished by the Product Area Quality Professional or designee review and approval of inspection and test reports, material certificates for source material, laboratory test reports and any other special document(s) generated during manufacturing.

15 The status of tests performed upon individual work orders of material is indicated on the traveler by signing off by production supervisor or inspectors.

Testing, examination, and inspection

reports are issued by SNT-TC-1A qualified inspectors for nondestructive testing and inspectors for final inspection in accordance with Control Procedures and Instructions. See Section 8, 20

"Control of Examinations, Tests, and Nonconforming Material" of this Manual.

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SANDVIK MATERIALS TECHNOLOGY

QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

CONTROL OF EXAMINATIONS, TESTS, AND NONCONFORMING MATERIAL

Section: 8.5 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 1

Of: 2

Control of Nonconforming Material

If material or product is suspected to be nonconforming to the Code or any other applicable requirements anytime during the processing, including receiving verification and incoming inspection, the suspect material or product shall have a yellow Hold Tag (EXHIBIT 7) or a uniquely numbered Nonconforming Material Report (NCMR) (EXHIBIT 17) or a red Reject Tag 5

(EXHIBIT 5) referencing the NCMR number applied or shall be scrapped immediately using the scrap bins/hoppers throughout the facility. The yellow hold tag shall contain the work order number as a minimum, and shall remain on the material or product until it has been established by the Product Area Quality Professional or designee whether a nonconformance exists or if the material or product can be reworked or reprocessed. If the material or product is found to be

10

nonconforming, the inspector shall remove the yellow hold tag, create an NCMR and tag the material or product with a copy of the NCMR or a red reject tag. When the material or product is scrapped immediately, the quantity and reason for the scrapping shall be recorded on the traveler by the inspector or production supervisors.

15

All material or product, which has been rejected (regardless of reason), is segregated by the inspector.

The inspector administers the use of the reject tags and is responsible for the

recording of the necessary information from the nonconformance to the tags.

He is also

responsible for the distribution of the reject information. The hard copy of the tag is attached to the material or product, and all relevant information is electronically transmitted to Product Area 20

Quality Professional for disposition of the material. When there are several loose units included on rejection tag, such as several skids of material, additional red reject tags will be attached by the inspector to each individual item, and this tag shall be marked with the number of the original NCMR.

25

The Product Area Quality Professional maintains a Nonconforming Material Report as the permanent record of all rejections and dispositions of reject material or product.

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

CONTROL OF EXAMINATIONS, TESTS, AND NONCONFORMING MATERIAL

Section: 8.5 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 2

Of: 2

Control of Nonconforming Material

The Product Area Quality Professional or his designee approves the disposition of all nonconforming material or product. The Product Area Quality Professional may decide and then issue the disposition. When deemed necessary by the Product Area Quality Professional, the disposition will be made by representatives of Quality Assurance, Sales, Materials, or Production. 5 When material or product received from outside suppliers is found to be non-conforming or suspect during receiving verification, incoming inspection or any later stage of manufacturing or processing, the supplier will be notified when necessary by the Product Area Quality Professional of the reason for rejection by the forwarding to them of the applicable Nonconforming Material 10

Report.

To insure that the disposition is carried out, when the material or product is disposed of per instructions, the hard copy of the reject tag, which was physically attached to the material, or product is removed by the person verifying the disposition. This person shall remove the tag 15

when the disposition of the material or product is satisfactorily carried out. This person will then forward the necessary disposition information to the Product Area Quality Professional or designee. The Product Area Quality Professional or designee will then use this information to generate the necessary objective evidence of proper material or product disposition.

20

When disposition of nonconforming material or products is complete, the Product Area Quality Professional shall review the nonconformance for possible corrective action in accordance with Section 9.2, "Corrective Action" of this Manual.

Nonconforming material or product that cannot be used for further processing and must be 25

scrapped shall be segregated and identified as scrapped material or product(s).

The

identification can be made by tags, marking by paint, cutting up to short lengths or collected in scrap bins prior to disposal.

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

AUDITS AND CORRECTIVE ACTIONS

Section: 9.1 Issue: 3 Revision: 1 Date: 01/03/2011

Audits Page: 1

Of: 2

In order to have independent internal control and provide timely feedback information in the effectiveness of the entire Quality System Program, planned and periodic audits are performed per Control Procedure and Instructions by an audit team such that the entire program is audited annually. The timing shall be established by a schedule maintained by the Director/Manager, 5

Quality and Metallurgy for such audits. It will be the responsibility of the audit team by the use of checklists approved by the Lead Auditor to determine that quality activities as documented in the Quality Assurance Manual and Control Procedures and Instructions are effective and being followed correctly. It is also their responsibility to identify problem areas and initiate corrective action. The audits shall also determine that the document control system for Quality System

10

documents per Section 3.3, "Document Control" of this Manual is effective.

Internal audits are directed by a lead auditor whose qualification shall be based on education and experience; (Appendix 2A-3 of ANSI/ASME NQA-1, 2008 Edition, 2009a Addenda shall be used), training and written examination (passing an internally administered qualification examination or a 15

grade/certificate from an externally assessed Lead Auditor Training Course and Examination), and audit participation (participated in a total of five (5) audits within three years) per an approved Control Procedure and Instruction, and designated as a lead auditor by the Director/Manager, Quality and Metallurgy, and are performed by persons knowledgeable in the area being audited. Qualification of internal audit team members is covered in separate Control Procedures and

20

Instructions and shall be accomplished by the audit team leader through a pre-audit briefing. This briefing will consist of the following topics:

1. Description of basic Quality System and review of Manual. 2. Review of present Control Procedures and Instructions. This review is done to enable 25

the audit team to know what guidelines should be used in auditing specific areas. 3. Review of audit checklist and areas to be audited. 4. Manner in which the audit is to be performed.

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QUALITY MANUAL ASME Code Section III

PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE AND HEATING TECHNOLOGY

AUDITS AND CORRECTIVE ACTIONS

Section: 9.1 Issue: 3 Revision: 1 Date: 01/03/2011

Audits Page: 2

Of: 2

5. Review of last internal audit report.

Written evidence of the briefing shall be placed in the internal audit file. The audit team shall consist of representatives drawn from various functions within the organization, as appointed by 5

the audit team leader. The audit shall be designed so that when a particular area is being audited, the person(s) performing the audit in this specific area shall not have direct responsibility for the activity being performed. This specifically includes the Quality Assurance Department. Audit results shall be recorded on the audit checklist.

10

To supplement the internal audit of the Quality Assurance Department, external SMT qualified lead auditors may be utilized to audit Quality Assurance activities on a biannual basis, at a minimum.

Formal audit reports shall be issued by the audit team leader within seven days and submitted to 15

responsible product area management for review including the President, Sandvik Materials Technology, the Vice President, Product Area Tube, the Production Unit Manager – Product Area Tube, the Vice President, Product Area Wire, and the Director/Manager, Quality and Metallurgy. The Director/Manager-Quality & Metallurgy shall also be provided with a copy of the audit checklists. It shall be the responsibility of the audit team leader to initiate corrective action per

20

Section 9.2, "Corrective Action" of this Manual for the audit findings. The Director/Manager, Quality and Metallurgy shall cause follow-up of audit findings to assure adequate resolution. The completed Corrective Action Report shall be reviewed for objective evidence of corrections of the findings.

A follow-up audit may be required when considered necessary by the

Director/Manager, Quality and Metallurgy.

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PRODUCT AREA TUBE

* * * PRODUCT AREA WIRE

AUDITS AND CORRECTIVE ACTION

Section: 9.2 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 1

Of: 2

Corrective Action

A corrective action program is established and documented in a Control Procedure and Instruction to assure prompt identification of discrepancies and conditions adverse to quality. The Product Area Quality Professional is responsible for reporting these conditions to the management of the area where the discrepancies are found on a Corrective Action Report 5

(EXHIBIT 19 for tubular products and welding products). These areas include but are not limited to: Production Departments, Sales Departments, Purchasing, Traffic, Quality Assurance, suppliers of materials and products, subcontracted services, customer complaints and reports of product nonconformities.

10

Quality Assurance shall use the Corrective Action Report to identify the discrepancy, the requirement and may provide a recommendation. The Report will be sent to the responsible individual requesting the cause of discrepancy, action taken to correct the discrepancy, action taken to prevent recurrence, and to eliminate the root cause of nonconformities. The responsible individual shall also indicate the timing required for completion. The Corrective Action Report is

15

used by Quality Assurance for documentation and for reporting corrective action to appropriate levels of management within Sandvik Materials Technology.

A time limit shall be specified for the reply. When the response indicates that the corrective action has been implemented promptly, the Product Area Quality Professional shall ensure that 20

corrective action was taken and that it is effective.

When the corrective action cannot be

immediately implemented, the Product Area Quality Professional shall follow up, verify, and document the implementation of the corrective action within an appropriate time frame, based on the estimated completion date, to ensure that it is effective and in place. If the response is found to be inadequate or ineffective, a second Corrective Action shall be escalated to a higher level of 25

management by the Product Area Quality Professional.

Repetitive nonconformances and trends shall be considered by the Product Area Quality Professional. For repetitive nonconformances and trends, a separate Corrective Action Report

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AUDITS AND CORRECTIVE ACTION

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Date: 04/08/2009

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Corrective Action

shall be issued by the Product Area Quality Professional. The analysis shall be reported to and actions followed up by the Product Area Quality Improvement Teams or Management Teams.

Based on the results of corrective actions and trends, changes to documented procedures shall 5

be made as needed.

When defective material or products or conditions adverse to quality are identified as resulting from material supplier or subcontractor nonconformance and requiring corrective action as determined by the Product Area Quality Professional, a Nonconforming Material Report (EXHIBIT 10

17) which refers to a Corrective Action Report for Tubular Products and for Welding Products (EXHIBIT 19) shall be issued by the Product Area Quality Professional.

Vendors and subcontractors not providing adequate corrective action shall be removed from the Approved Supplier List for ASME Section III and Military Applications. For ASME Code Section 15

III requirements, this removal shall be made by the Director/Manager, Quality and Metallurgy.

Rules for reporting of safety-related defects and noncompliances per 10CFR21 are established in an approved Control Procedure and Instruction.

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CERTIFICATION REQUIREMENTS

Section: 10 Issue: 3 Revision: 0

Date: 04/08/2009

Page: 1

Of: 2

A Certified Material Test Report (CMTR) shall be furnished, certifying conformance to specification or customer requirements.

Material Certificates (Certified Material Test Reports -- EXHIBIT 20) for Code material and MIL 5

specification material shall be prepared and signed by the Director/Manager, Quality and Metallurgy or designee. A prior review of the material purchase and production records shall have been made to assure the Director/Manager, Quality and Metallurgy or desigee, that all requirements of the customer's purchase order have been met.

10

The Certified Material Test Report (CMTR) shall affirm that the contents of the report are correct and accurate and that all test results and operations performed by Sandvik Materials Technology or its subcontractor are in compliance with material specification and the specific applicable material requirements of the ASME Code Section III. It shall include the actual results of all required chemical analysis, tests and examinations and specific times, temperature ranges and

15

cooling rates, where applicable, to the heat treatment of pipe, tubes and weld test specimens. Chemical analysis, tests, examinations and heat treatments required by the purchaser that were not performed shall be indicated.

The applicable Sandvik ASME Quality System Certificate

Number and expiration date shall be included on the certificate for Code material when the requirements of this Quality Manual have been met. 20 The certification shall identify the applicable material by heat and/or lot number and shall include the test results and operations performed by Sandvik and identify those performed by its subcontractors.

All approved certifications received from other Material Organizations or

approved suppliers for required chemical analysis (including melting mill heat analysis), heat 25

treatments, tests and examinations shall be furnished as an identified attachment to the Certified Material Test Report. When operations other than chemical analysis, heat treatments, tests and examinations are subcontracted, these operations and the approved suppliers performing these activities shall be listed on the Certified Material Test Report, or the approved suppliers

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CERTIFICATION REQUIREMENTS

Section: 10 Issue: 3 Revision: 0

Date: 04/08/2009

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Of: 2

certification for the operation shall be furnished as an attachment to the Certified Material Test Report.

Where Sandvik supplies and certifies material procured from another Material Organization per 5

ASME Code Section III requirements, the certificate shall affirm that the contents of the report are correct and accurate and that all test results and operations performed by Sandvik Materials Technology or its subcontractor are in compliance with material specification and the specific applicable material requirements of the ASME Code Section III; and identify the applicable material by heat and/or lot number, and include those operations performed by Sandvik and

10

identify those performed by its subcontractors.

Sandvik shall, as a Material Organization,

transmit with this certificate a copy of producing Material Organization’s Certified Materials Test Report, and subcontractor’s certificate, and shall include the Sandvik Quality System Certificate Number and expiration date on the Sandvik Certified Material Test Report (CMTR), when the requirements of this Manual have been met. 15 When product form conversion is performed, the Certificate shall state that the material conforms to the applicable dimensional requirements of the material specification and the ASME Code Section III.

20

Sandvik will supply upon request any additional records of any subcontracted service, plus a statement of compliance with all materials.

When unqualified source material is used, per ASME Code Section III requirements, Sandvik shall transmit the source material manufacturer's heat analysis and the CMTR shall include the 25

product analysis of each piece of source material used. In addition, the result of all other tests, examinations or treatments per the Material Specification, shall be included on the Certified Material Test Report for each piece of source material.

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Section: 11.1 Issue 3 Revision: 0 Date: 04/08/2009

FORMS AND DOCUMENTS List of Forms and Documents

Page: 1

Of: 1

The below-listed forms and documents are examples of those used in the Quality Systems. Modifications to these forms and documents can be made without revising this section of the Manual, provided the forms and documents, as a minimum, contain all of the information from the superseded form/document(s). However, at the next issuance of the manual, all forms shall be brought up to their current revision regardless. EXHIBIT NUMBER TITLE 1 Sales Order

REVISION NUMBER 0

REVISION DATE 04/08/2009

2

Specification Review Sheet/Product Requirements Review for Tubular Products

0

04/08/2009

3

Specification Review Sheet/ Product Requirements Review for Welding Material and Wire Products

0

4

Laboratory Request Item Form

0

5

Reject Tag

0

04/08/2009

6

Quality Manual Acknowledgment Letter

0

04/08/2009

7

Hold Tag

0

04/08/2009

8

Tube Production Work Order (Shop Traveler)

0

04/08/2009

9

Welding and Wire Production Work Order (Shop Traveler)

0

04/08/2009

10

Bundle Identification Tag for Tubular Products

0

04/08/2009

11

Final Inspection Form for Tubular Products

0

04/08/2009

12

Material Identification Tags (Welding and Wire Products)

0

04/08/2009

13

OK to Process Tag

0

04/08/2009

14

Laboratory Test Report (Tubular Products)

0

04/08/2009

15

Eddy Current Test Report (Tubular Products)

0

04/08/2009

16

Ultrasonic Test Report (Tubular Products)

0

04/08/2009

17

Nonconforming Material Reports

0

04/08/2009

18

Process Control Plan/Quality Control Plan (SAMPLE)

0

04/08/2009

19

Corrective Action Report (Tubular and Welding Products)

0

20

Certified Material Test Reports (Tubular and Welding Products)

0

21

In-Process and Final Inspection Report for Bare Electrodes, Rods, and Welding Products Cut or Spooled by Sandvik Materials Technology

0

04/08/2009 04/08/2009

04/08/2009 04/08/2009 04/08/2009

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FORMS AND DOCUMENTS

Section: 11.2 EXHIBIT 1 Issue: 3 Revision: 0 Date: 04/08/2009

Sales Order Page: 1

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Section: 11.2 EXHIBIT 2 Issue: 3 Revision: 0 Date: 04/08/2009 Page: 1

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Section: 11.2 EXHIBIT 2 Issue: 3 Revision: 0 Date: 04/08/2009 Page: 2

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Section: 11.2 EXHIBIT 2 Issue: 3 Revision: 0 Date: 04/08/2009 Page: 3

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Section: 11.2 EXHIBIT 3 Issue: 3 Revision: 0 Date: 04/08/2009 Page: 1

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Section: 11.2 EXHIBIT 3 Issue: 3 Revision: 0 Date: 04/08/2009 Page: 2

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Section: 11.2 EXHIBIT 4 Issue: 3 Revision: 0 Date: 04/08/2009

FORMS AND DOCUMENTS Laboratory Request Item Form

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Quality Manual Acknowledgment Letter Page: 1

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Section: 11.2 EXHIBIT 8 Issue: 3 Revision: 0 Date: 04/08/2009

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Welding and Wire Production Work Order (Shop Traveler) Page: 1

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Section: 11.2 EXHIBIT 10 Issue: 3 Revision: 0 Date: 04/08/2009

Bundle Identification Tag for Tubular Products Page: 1

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Section: 11.2 EXHIBIT 11 Issue: 3 Revision: 0 Date: 04/08/2009

Final Inspection Form for Tubular Products Page: 1

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Section: 11.2 EXHIBIT 12 Issue: 3 Revision: 0 Date: 04/08/2009

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Section: 11.2 EXHIBIT 14 Issue: 3 Revision: 0 Date: 04/08/2009

Laboratory Test Report (Tubular Products) Page: 1

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Ultrasonic Test Report (Tubular Products) Page: 1

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Section: 11.2 EXHIBIT 17 Issue: 3 Revision: 0 Date: 04/08/2009

FORMS AND DOCUMENTS Nonconforming Material Reports

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Electronic Format – All Areas

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Nonconforming Material Reports Page: 2

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Section: 11.2 EXHIBIT 17 Issue: 3 Revision: 0 Date: 04/08/2009

Nonconforming Material Reports Page: 3

Electronic Format – NADC Only!

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Section: 11.2 EXHIBIT 18 Issue: 3 Revision: 0 Date: 04/08/2009

Process Control Plan/Quality Control Plan (SAMPLE) Page: 1

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Section: 11.2 EXHIBIT 19 Issue: 3 Revision: 0 Date: 04/08/2009

Corrective Action Report (Tubular and Welding Products) Page: 1

ELECTRONIC FORMAT (INTERNAL CORRECTIVE ACTION) – ALL AREAS

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Section: 11.2 EXHIBIT 19 Issue: 3 Revision: 0 Date: 04/08/2009

Corrective Action Report (Tubular and Welding Products) Page: 2

ELECTRONIC FORMAT (SUPPLIER CORRECTIVE ACTION) – ALL AREAS

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Section: 11.2 EXHIBIT 19 Issue: 3 Revision: 0 Date: 04/08/2009

Corrective Action Report (Tubular and Welding Products) Page: 3

ELECTRONIC FORMAT (SUPPLIER CORRECTIVE ACTION) – ALL AREAS

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Section: 11.2 EXHIBIT 20 Issue: 3 Revision: 0 Date: 04/08/2009

Certified Material Test Reports (Tubular and Welding Products) Page: 1

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Section: 11.2 EXHIBIT 20 Issue: 3 Revision: 0 Date: 04/08/2009

Certified Material Test Reports (Tubular and Welding Products) Page: 4

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Section: 11.2 EXHIBIT 21 Issue: 3 Revision: 0 Date: 04/08/2009

In-Process and Final Inspection Report for Bare Electrodes, Rods, and Welding Products Cut or Spooled by Sandvik Materials Technology Page: 1

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In-Process and Final Inspection Report for Bare Electrodes, Rods, and Welding Products Cut or Spooled by Sandvik Materials Technology Page: 2

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