Construction QC/QA Plan
The United States Environmental Protection Agency (EPA) issued a Superfund Record
of Decision (ROD) on February 1, 2002 (EPA, 2002) calling for, among other things, the dredging and disposal of certain sediments from the Upper Hudson River containing polychlorinated
biphenyls (PCBs). On August 18,
2003, the General Electric Company (GE) and EPA entered
into an Administrative Order on Consent for Hudson River Remedial Design and Cost Recovery
(RD AOC) (Index No. CERCLA-02-2003- 2027) (EPA/GE, 2003), under which GE agreed to design
the remedy outlined in the ROD.
On October 6, 2005, the Consent
Decree (CD) for the remedial action (RA) in the Upper
Hudson River (Civil Action
1:05-CV-1270) was filed in Federal
Court. After an extensive
public review and comment period, the court approved
and entered the CD as a final judgment on November 2, 2006, when it
went into effect (EPA/GE, 2005).
GE prepared the Phase
1 Final Design Report (FDR) (BBL, 2006) and submitted it to EPA
on March 21, 2006. On May 31, 2006, EPA approved the portion of the FDR that included
the facility site work construction (Contract
1) and rail yard construction
(Contract 2). However,
EPA has not yet approved the designs for the access road and the work support marina.
Included as Appendix B to the CD is the Statement of Work for Remedial Action and Operations,
Maintenance and Monitoring (SOW) which sets forth a number of requirements for implementing the remedial action set forth in the ROD. Section
2.1.2 of the SOW
requires that a Construction Quality Control / Quality Assurance Plan (CQAP) be provided to EPA for review and approval. This document is being submitted to satisfy that requirement.
1.1 PROJECT SETTING
The Upper Hudson River is defined
as the section of river from the Fenimore Bridge
in Hudson Falls to the Federal Dam at Troy, New York. The ROD calls for, among other things, a remedial action to remove and dispose of sediments from
the Upper Hudson River. Sediments to be removed
are defined based on the PCB mass per unit area (MPA)
and surface concentration or characteristic criteria (EPA,
2002).
EPA defined three sections of the Upper Hudson River for the sediment
remediation activities outlined in the
2002 ROD:
• River Section 1: Former
location of Fort Edward Dam to Thompson Island Dam (TID) (from river mile [RM] 194.8 to RM 188.5; approximately
6.3 river miles);
Construction QC/QA
Plan
• River Section 2: TID to Northumberland Dam (from RM 188.5 to RM 183.4; approximately 5.1 river miles);
and
• River Section 3: Northumberland
Dam to the Federal Dam at Troy
(from RM 183.4 to RM 153.9; approximately 29.5 river miles).
The remedial action
is to be conducted in two phases, designated Phase 1 and Phase 2.
Phase 1 is defined as the first year of dredging and will be completed in a portion
of River Section 1. Phase
1 also includes preparation of the land-based sediment processing facility. Phase 2 covers the remaining
dredging in the three river sections.
1.2 PHASE 1 CONTRACTS DESCRIPTION
The project scope for Phase 1 activities will be conducted under at least seven separate contracts (excluding the rail transport and disposal
contracts as well as agreements with the originating
rail carrier for infrastructure improvements) and three separate Remedial
Action Work Plans (RAWPs). The contracts and RAWPs are described below and summarized
in Table 1-1. The table also includes the relationship of construction quality
assurance (QA), quality
control (QC) and health and safety
to other Phase 1 activities.
Table 1-1. Organization
of Phase 1 RA Work Plans
|
Phase 1 Contract Packages |
Remedial
Action Work Plans |
Construction Quality Assurance Plans |
Remedial
Action Health
and Safety
Plan |
|
Contract 1 – Facility
Site Work Construction |
RA Work Plan #1 Phase
1 Facility Site Work
Construction |
Construction Quality Control/Quality Assurance
Plan |
One umbrella RA Health and Safety
Plan |
|
Contract
2 – Rail Yard Construction |
|||
|
Contract
3A – Processing Facility Construction |
RA Work Plan #2 Phase 1 Processing Equipment Installation and
Remaining Site Work |
||
|
Contract
3B – Processing Facility Operation |
RA Work Plan #3 Phase
1 Dredging and Facility Operations |
Dredging
Construction Quality Control/Quality Assurance Plan |
|
|
Contract
4 – Dredging Operations |
|||
|
Contract 5
– Habitat Construction |
|||
|
Contract
6 – Rail Yard Operations |
The activities to be performed under Contract
1 (Facility Site Work Construction) and Contract
2 (Rail Yard Construction) are presented in detail in Sections 2 through 7 of RAWP
#1,
Construction QC/QA Plan
Remedial Action Work Plan for Phase 1 Facility Site Work Construction (Parsons,
2007). These activities include the following:
• Contract 1 – Facility Site Work Construction
includes general civil work, such as grading, placement and compaction of fill and paving.
Other work activities include
wharf area construction, access road construction, river mooring installation and
construction of a support marina.
• Contract 2 – Rail Yard Construction includes rail construction on the processing
facility site property, and within the right-of-way of the commercial rail carrier, and rail yard facilities work.
The activities to be performed under Contract 3A – Processing Equipment Installation will be described in RAWP
#2, Remedial Action Work Plan for Phase 1 Processing Equipment Installation and Remaining Site Work. RAWP #2 covers the remaining site work,
such as processing facility buildings, and the installation of process equipment, piping, electrical,
instrumentation, communications, and the commissioning of the systems.
The scope of work under Contract 3B, Contract 4, Contract
5, and Contract 6 will be addressed in RAWP #3,
Remedial Action Work Plan – Phase 1 Dredging and Processing
Facility Operations. Briefly,
RAWP #3 covers the following:
• Contract 3B – Processing Facility Operations, including barge offloading, coarse
material separation, sediment dewatering, water treatment (process
and stormwater), stormwater management, and staging area management and maintenance. In the off season
(when the Champlain Canal is closed),
the contractor will winterize the
processing facility and operate
and maintain the stormwater collection and treatment system.
• Contract
4 –
Dredging Operations,
including resuspension containment system installation, debris removal,
the performance of inventory
and residual dredging operations and the transport
of loaded sediment barges to the off-loading wharf at the processing facility. After dredging
is completed in an area, the contractor will place
appropriate backfill, cap, or
shoreline stabilization structures.
• Contract 5 – Habitat Construction, including the supply and planting of subaquatic
vegetation in certain dredged areas pursuant to habitat reconstruction plans.
• Contract 6 – Rail Yard Operations, including all activities required to operate and maintain the rail yard. This primarily will involve the loading of debris,
coarse material and dewatered
sediment into empty rail cars, setting up of outbound
loaded trains, and receiving of inbound empty trains.
1.3 QUALITY PROGRAM
OVERVIEW
GE's approach to management of the quality of the RA implementation
includes a combination
of quality control by the contractor and quality assurance by the Construction
1-3
Construction QC/QA
Plan
Manager. The
CQAP
details the systems and controls that
GE
has put in place
so that the quality of the project will meet the requirements specified in the Phase 1 FDR. GE provides definition
and overall management of the quality
approach to be followed
by its contractors and
consultants. The quality
of the RA implementation will be ensured through
an integrated system of
quality assurance performed by the Construction Manager and quality control provided by the contractors. GE's
Construction Manager is responsible
for the day-to-day
coordination of quality
assurance and quality control measures in the field.
This Construction Quality Control/Quality
Assurance Plan (CQAP) is a companion document
to RAWP #1 and RAWP #2. It establishes:
• project procedures
and general responsibilities for the quality assurance
and quality control (QC/QA)
program; and
• protocols to ensure that the Phase 1
Facility Site Work Construction
(FSWC) and Process Equipment Installation (PEI) will be executed in accordance with the
relevant portions of the Phase 1 FDR.
This CQAP has been developed in accordance with
Section 2.1.2 of the SOW.
The contractors are responsible for constructing the work in accordance with the plans and specifications. Each contractor is also responsible for controlling the quality of its work to meet
contract plans, specifications, and related requirements. The contractor’s QC is the systematic
implementation of a program of inspections, tests, and production
controls to attain the required standards of quality and to preclude problems resulting from noncompliance. Pursuant to
Technical Specification Section 01400 Quality Requirements,
each contractor will establish an independent
QC program and write a Contractor Quality Control Plan (CQCP).
The CQCP must provide for tests and inspections pursuant to various technical
specifications. It will define
procedures to ensure that activities affecting quality are properly documented and accomplished in accordance with contract documents;
written instructions;
and industry standards, codes and
procedures. Furthermore, the CQCP will define methods for ensuring that activities
affecting quality will be accomplished under controlled conditions.
Independently of the contractors, the construction manager (CM) will provide QA through
daily monitoring and scheduled inspections to verify the effectiveness of the contractor’s QC program and assure that the quality
and contract requirements are met by the contractors. The
CM assures that the contractor’s QC is working effectively, and that the resultant construction complies with the
quality requirements established
by the contract.
The objectives of this CQAP are to:
• Describe the quality program and organization
to be implemented so that the project is constructed in accordance with the
contract requirements and industry standards.
Construction QC/QA
Plan
• Describe guidelines for inspection and documentation of construction
activities;
• Provide reasonable
assurance that the completed work will meet or exceed the
requirements of the construction drawings and specifications; and
• Describe how any unexpected changes or conditions that could affect the construction
quality will be detected, documented,
and addressed during construction.
1.4 QUALITY MANAGEMENT PLAN
Parsons Engineering of New York, Inc. (Parsons) has been retained to provide
construction management services for this project. As GE’s managing contractor, Parsons will carry out work on this project
in accordance with the Parsons
Quality Management Plan (QMP) (Parsons, 2005), which was submitted to EPA on November 1, 2005.
1.5 CQAP ORGANIZATION
This CQAP
is organized into eleven
sections.
• Section 1 -
Introduction: describes the project setting,
the Phase 1 contracts and
related RAWPs, and the CQAP quality
program overview.
• Section 2 - Project QC/QA Organization: presents
the organizations and key
personnel involved in the construction of the RA, their responsibilities and authorities, the structure of the QC/QA organization and the minimum training
and experience of the Construction Quality Assurance Officer (CQAO) and personnel.
• Section 3 - Submittals: presents the procedures for processing submittals from
Phase 1 contractors and vendors.
• Section 4 - Performance Monitoring Requirements: addresses QC/QA
for performance monitoring
requirements applicable to
Phase 1 FSWC and PEI.
• Section 5 -
Inspection and
Verification Activities: provides
procedures for tracking construction inspection and verification activities for the contract, construction
acceptance criteria, and construction
audits.
• Section 6 - Construction Deficiencies: describes the procedures for tracking construction
deficiencies from identification through acceptable corrective action.
• Section 7 -
Documentation: describes the procedures for the project documents that
will be managed through a combination of a
secure document filing and
storage system and computerized Document
Tracking System.
• Section 8 -
EPA Approvals: describes
EPA approvals applicable
to the Phase 1 FSWC and PEI QC/QA.
• Section 9 - Field Changes: describes handling of quality plan changes to assure QC/QA objectives are met.
Construction QC/QA Plan
• Section 10 -
Final Reporting: describes
the QC/QA documentation for Phase
1 FSWC and PEI to be submitted to EPA in the Phase
1 Construction Completion Report.
• Section 11 - References: provides bibliographic references to key documents referred to in the body of the plan.
Construction QC/QA Plan
SECTION 2
PROJECT QC/QA ORGANIZATION
This section presents the responsibilities and authorities of organizations and key personnel involved in the construction of the RA, the structure of the QC/QA organization, the minimum training and experience of the QC/QA personnel, and the QC/QA training given to all onsite workers.
2.1 RESPONSIBILITIES AND AUTHORITIES OF ORGANIZATIONS
The organizations involved in the Phase 1 FSWC and PEI and their QC/QA roles and responsibilities are as follows.
2.1.1 Environmental Protection Agency
EPA is the lead agency responsible for observing and monitoring the progress of the Phase 1 FSWC and PEI in accordance with the CD. As such, EPA exercises approval authority for this CQAP.
2.1.2 General Electric Company
GE is responsible for implementing the RA in accordance with the CD and for ensuring that its contractors and subcontractors perform RA construction in accordance with the CD.
The CQAP details the systems GE has put in place in order that its responsibilities to quality are met. GE is responsible for verifying that the CM it has retained effectively implements and manages the systems detailed in the CQAP. GE is also responsible for formal communications with and submittals to EPA.
2.1.3 Engineer of Record
The Engineer of Record is an independent,
duly qualified, licensed
design professional, retained directly by GE to provide design and engineering services in connection with the
project. This definition includes all
subcontractors to the Engineer of Record.
Blasland, Bouck
and Lee, Inc. (BBL)
is the Engineer of Record for Phase 1 except for the rail
yard. HDR Engineering, Inc. (HDR) is the Engineer of Record for the rail yard. BBL and
HDR provide submittal review and resolution of design issues as they arise
during construction.
2.1.4 Construction Manager
The CM is a duly qualified entity retained by GE to provide professional construction management and related services in connection with the project. The CM is responsible for
implementation of this CQAP.
and serve as the primary point of contact with the contractors for all communications to and from the contractors. The CM will provide Quality Assurance and monitor the day-by-day construction quality control activities performed by construction contractors to verify compliance with the contract plans and specifications. The CM will also manage, coordinate, and administer all QC/QA activities and requirements, including those of subcontractors to the CM. Additionally, the CM may be assigned management of any third party QA inspection and testing firms retained by GE.
2.1.5 Construction Contractors
The construction contractors are retained by GE to provide the labor, materials and equipment required to construct the project in accordance with the contract documents. Construction contractors are responsible for the quality control of their constructed work product as well as the necessary inspections and tests required to ensure that their work complies with the contract documents. They exercise authority over their workforce, including QC personnel and their third-party QC support services.
Pursuant to Specifications Section 01450, each contractor will submit a QC organization chart developed to show all QC personnel and how these personnel integrate with other management, production and construction functions and personnel. All QC staff members are subject to acceptance by GE. The requirements for the QC organization include a QC Systems Manager and a sufficient number of additional qualified personnel to ensure contract compliance. The contractor is to provide a QC organization that is represented on the site at all times during progress of the work and with authority to take any action necessary to ensure compliance with the contract.
2.2 STRUCTURE OF QC/QA ORGANIZATION
The QC and QA functions of the project organizations are functionally integrated although
contractually separate. Figure 2.1 shows the functional structure of the project
QC/QA team.
Key personnel involved in the Phase 1 FSWC and PEI and their QC/QA roles and
responsibilities are described below in Section
2.3.1 and Section 2.3.2. Pursuant
to the CD statement of work, names of QC/QA personnel
assigned CQAP functions are to be communicated to EPA; these personnel are the CQAO and CM Field Inspectors. Since personnel assignments are subject to change over time, the CM will maintain
a CQAP Staffing List of CQAP personnel assignments including
each person’s role and organization. This CQAP
Staffing List is initially provided in Attachment 1 together with resumes of current CQAP personnel. When personnel changes occur, GE will provide an updated Attachment 1 to EPA.
Construction Manager
The Construction Manager (CM) is the primary point of contact for GE on all construction management issues. The CM is responsible for the overall management of activities related to the construction program, including the implementation of the CQAP and the health and safety program. As such, the CM will work directly with GE to exercise approval authority over contractor submittals including the CQCP. The CQCP must include the names and qualifications of contractor’s QC personnel pursuant to Section 2.3.2 below.
Site Manager
The Site Manager (SM) monitors and works with GE to approve each contractor’s quality, and progress submittals to ensure that the project is meeting the contract requirements. The SM will manage the field implementation of the CQAP at the project sites under control of the senior field engineer (FE) and the Construction QA Officer.
Construction Quality Assurance Officer
The CQAO is a full-time employee of the CM. The CQAO should have a minimum of five years of experience in related construction and prior QA experience on a project of comparable size and scope to this project. Additional qualifications for the CQAO include one or more of the following requirements:
• P.E. with one year of related construction experience acceptable to GE.
• Engineer in Training (EIT) with two years of related
construction experience
acceptable to GE.
• Three years of related experience acceptable
to GE with a Bachelor of Science Degree
in civil engineering, civil engineering
technology, or construction.
• Construction materials technician certified at Level III by National Institute for Certification in Engineering Technologies (NICET).
The CQAO reports directly to the CM. The CQAO will have full authority delegated by the CM and GE to institute actions necessary for the successful implementation of the QC/QA program to ensure compliance with the contract plans and technical specifications (including stop-work authority). The CQAO is assigned to the project full time.
The CQAO works with GE to administer and implement the CQAP. This includes controlling this CQAP, making revisions as necessary, and implementing systematic actions to ensure compliance with the plan. The CQAO coordinates activities with the SM to ensure that the FE, inspection staff, third party inspection and testing firms as well as contractor QC staff carry out the requirements of the CQAP.
Construction QC/QA Plan
The CQAO is supported by Parsons’ QA Services. Parsons QA staff will provide expertise, on an as-needed or as-requested basis, in the investigation and handling of significant or unique quality issues.
The CQAO tracks and reports non-conformances to the CM, SM, and after notification to the CM, to contractor management and contractor QC staff. The CQAO also has full authority to obtain direct access to contractor QC files. Other CQAO responsibilities include:
• Reviewing contractor QC reports, tests, and inspection results;
• Facilitating the implementation of the four-phase
inspection program and participating in the required inspections; and
• Ensuring that QA personnel conducting inspections are adequately trained and understand assignment limits and time frames.
Senior Field Engineer
The Senior Field Engineer (FE) administers the contract requirements, including the CQCP submittals by contractors, and assures that each contractor consistently conforms to its approved CQCP. The FE oversees inspection efforts, provides technical advice, and coordinates support from engineering support, administration, inspection services, safety, and other team members.
The FE coordinates resolution of unsatisfactory work items with contractors through final acceptance. The FE assures open noncompliance report (NCR) items are completed and accepted in a timely fashion. Acting in concert with GE, the SM and CQAO, the FE has the authority to require changes to the contractor’s QC organization and plan as required to address apparent trends, to mitigate future NCRs and to obtain the quality specified in the contract documents.
The FE reviews QC and QA testing documentation with contractors, engineers, and inspectors. The FE also reviews plans and specifications for assigned projects and estimates the type and number of QA tests that should be accomplished for each specification section. The FE meets with third-party testing and inspection firms to review test requirements and coordinate testing and inspection services.
Field Inspectors
CM Field Inspectors (FIs) are responsible to the FE and support the FE’s administration of the construction contracts. The FIs will hold a bachelors degree in engineering or construction and have three years experience in the type of work being performed on this project, or will have at least five years of related experience and will hold the construction materials technician certified at Level III by the NICET. Certification at an equivalent level by a state or nationally recognized organization will be acceptable in lieu of NICET certification. For inspection of the NY Route 196 intersection construction, QA inspectors must meet NICET Level II or higher .
Construction QC/QA Plan
certification in highway construction. Additional experience and training may be substituted for educational requirements, subject to GE’s approval.
The FIs will monitor the day-to-day activities of the contractor. This includes ensuring that contractors comply with the plans and specifications, applicable building codes, good workmanship, and the QC requirements of the contract. As part of this effort, FIs will:
• conduct independent inspections to verify the quality of the work; • participate in
contractor four phase inspections;
• review test and inspection reports; and
• ensure that the required documentation is submitted.
The FIs must be alert to detecting, recording, and reporting any deviation from the contract documents, including
calling any deficient item to the attention
of the FE, the contractor’s
superintendent, and/or other representative. The FIs must keep accurate and detailed records of the contractor’s performance and progress, delivery
of materials, and other pertinent matters,
including the daily inspection
report.
QC Systems Manager
The QC Systems Manager (QCM) is a full-time employee of the contractor, or a consultant engaged by the contractor. The QCM should have a minimum of five years of experience in related construction and prior QC experience on a project of comparable size and scope to the contractor’s scope of work on this project. Additional qualifications for the QCM include at least one of the following requirements:
• PE with one year of related construction experience acceptable to the CM.
• EIT with two years of related construction experience acceptable to the CM.
• An individual with three years of related experience acceptable to the CM, with a
Bachelor of Science Degree in civil engineering, civil engineering technology, or construction.
• Construction materials technician certified at Level III by the NICET.
The QCM will have full authority to institute any and all actions necessary for the successful implementation of the QC program to ensure compliance with the contract plans and technical specifications. The QCM shall report directly to a responsible officer of the construction contractor. The QCM is assigned to this project full time.
QC Technicians
The contractor QC
Technicians perform the
following functions:
• Inspect all materials, construction,
plant, and equipment for conformance with the
technical specifications; and
• Perform all QC tests as required by the technical specifications.
Contractor QC Technicians will be engineers, engineering technicians, or experienced craftsmen with qualifications in the appropriate field equivalent to NICET Level II
or higher construction materials technician, and will have a minimum of two years of experience in their area
of expertise. For inspection of the NY Route
196 intersection construction, QC inspectors
must meet NICET Level II or higher certification in highway construction. Certification at an equivalent level by a state or nationally
recognized organization will be acceptable in lieu of NICET
certification. Additional
experience and training may be substituted for educational requirements, subject to GE’s approval.
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