Hello Bert, I would not call this a "TKY" application, I do believe that you need to have your welder(s) qualified for an all-position unlimited qualification (3G, 4G if the parts are more than a 3/4" tube or plate thickness that is being welded) as you have both overhead and vertical welding present if you are not rotating this item. If you are rotating this, then a partial certification encompassing the 3G position would suffice. Others can likely expand on my answer. Best regards, Allan