FUSRAP_St__Louis_QAPP_Sep_2015r2_apdf.pdf

QUALITY ASSURANCE PROGRAM PLAN (QAPP)

FOR

FUSRAP SITEWIDE QA ACTIVITIES

ST. LOUIS, MISSOURI DISTRICT

UNITED STATES ARMY CORPS OF ENGINEERS

FUSRAP –

ST. LOUIS, MO

Revised Sep 2015

Approved by: Approved Date:

Vick James – Area Engineer /Sr. Project Engineer

USACE St. Louis, MO b3cocvlj Typewritten Text 14 Sep 2015 b3cocvlj Typewritten Text

Table of Contents

List of Figures....................................................................................................................... iv List of Appendices ............................................................................................................... vi List of Acronyms and Abbreviations ...................................................................................vii Terms and Definitions.......................................................................................................... ix

1.0 Formally Utilized Sites Remedial Action Program

1.1 Background

1.2 Site History

1.2.1 SLDS

1.2.2 North St. Louis County Sites

1.2.2.1 SLAPS

1.2.2.2 SLAPS VPs

1.2.2.3 Latty Avenue Properties

2.0 Purpose and Scope

2.1 Specific FUSRAP Sitewide QAPP Items

2.1.1 QA Plan Review Process

2.1.2 Period Covered

2.1.3 Applicability

3.0 Staffing

3.1 Job Responsibilities

3.1.1 USACE FUSRAP Area Engineer

3.1.2 USACE FUSRAP ACOR

3.1.3 USACE FUSRAP Office Engineer

3.1.4 USACE FUSRAP Construction Representative

3.1.5 Construction Contractor Supplied Personnel

3.1.5.1 Construction Management Services

3.1.5.2 Environmental Services

3.2 Organizational Structure

4.0 Pre-construction Conference

5.0 QA during Design

5.1 Scheduling of Projects

5.2 Construction Reviews

5.3 Bid Reviews

5.4 QA Reporting and Testing

6.0 QA during Construction

6.1 Quality Assurance Activities

6.2 Three-Phase Inspection system

6.2.1 Preparatory Inspection

6.2.2 Initial Inspection

6.2.3 Additional Preparatory and Initial Phases

6.2.4 Follow-up Phase

6.2.5 Final Inspection

6.3 Quality Metrics Grading

6.4 Specialized Assistance

7.0 Documentation of QA Activities

7.1 Daily Quality Assurance Report

7.1.1 Review of Daily QC Paperwork

7.2 Weekly Quality Assurance Report

7.3 QA Deficiency Reporting

7.4 Non-Conformance Report

7.5 Final Status Survey Walkover and Sample Collection Protocol

8.0 Quality Assurance Audits/Surveillances

8.1 Contractor Records

8.1.1 Complete QA Audit/Surveillance

8.1.2 QA Audit/Surveillance of RAC Off-site Document Control System .. 32

8.1.3 QA Audit/Surveillance of RAC On-site Document Control System .. 33

8.2 Contracting Officer Representative Files

8.2.1 Contracting Officer Representative (COR) Files Audit

8.3 Radiation Instrument QA Audit/Surveillance

9.0 Conclusion

10.0 References

List of Figures

Figure Title

3-1 USACE Construction Organizational Chart

6-1 Quality Assurance Representative General Daily Duties

6-2 Quality Metric Grading

7-1 Daily Quality Assurance Report

7-1a Daily Quality Assurance Report Flowchart

7-2 Weekly Quality Assurance Report

7-3 QA Deficiency Report

7-4 QA Deficiency Log

7-4a QA Deficiency Flowchart

7-5 Non-Conformance Report

7-5a Non-Conformance Report Flowchart

7-6 Final Status Survey Walkover & Sampling Collection Checklist

7-6a USACE Meeting Minutes dated March 8, 2001

7-6b Final Status Survey Walkover & Sampling Collection Checklist Flowchart

8-1 Quality Assurance Audit/Surveillance

8-1a Quality Assurance Audit/Surveillance Flowchart

8-2 Document Control Off-site Random System Check

8-3 Document Control On-site Random System Check

8-4 Checklist for Contracting Officer’s Representative (COR) Files

List of Figures (continued)

8-4a Checklist for COR Files Flowchart

8-5 Radiation Instrumentation QA Audit/Surveillance

List of Acronyms and Abbreviations

ACOR Alternate Contracting Officer’s Representative AEC Atomic Energy Commission AHA Activity Hazard Analysis ARIMS Army Records Information Management System ASTM American Society for Testing and Materials CEMVS-EC-C Corps of Engineers, Lower Mississippi Valley Division, St. Louis District

– Engineering and Construction Division – Construction Branch CET Civil Engineering Technician COR Contracting Officer’s Representative CQC Contractor Quality Control CQCP Contractor Quality Control P lan CQCM Contractor Quality Control Manager DCGL Derived Concentration Guideline Level DFW Definable Feature of Work DO Delivery Order DOE Department of Energy DQAR Daily Quality Assurance Report DQCR Daily Quality Control Report EM Engineer Manual EPA Environmental Protection Agency FN File Number FSS Final Status Survey FSSE Final Status Survey Evaluation ft feet FUSRAP Formerly Utilized Sites Remedial Action Program FWV Field Work Variance HISS Hazelwood Interim Storage Site HQUSACE Headquarters United States Army Corps of Engineers IA Investigation Area IAAAP Iowa Army Ammunition Plant Mallinckrodt Mallinckrodt Chemical Works

List of Acronyms and Abbreviations (cont’d)

MED Manhattan Engineer District mi mile MO Missouri msl Mean Sea Level MVS USACE St. Louis District NCR Nonconformance Report NPL National Priorities List NTP Notice to Proceed NWK U.S. Army Corps of Engineers, Kansas City District PDI Pre-design Investigation QA/QC Quality Assurance/Quality Control QAPP Quality Assurance Program Plan QAR Quality Assurance Representative RA Remedial Action RAC Remedial Action Contractor RG Remediation Goals SAG Sampling and Analysis Guide SLAPS St. Louis Airport Site SLDS St. Louis Downtown Site SOP Standard Operating Procedure USACE U.S. Army Corps of Engineers VP Vicinity Property WD Work Description

Terms and Definitions

Assessment - An inclusive term meaning any of the following: audit, performance evaluation, management systems review, peer review, or surveillance performed by or for management.

Audit - A formal, planned and documented activity performed to determine, by investigation, examination, or evaluation of objective evidence, the compliance with established plans, procedures, instructions, drawings, and other applicable documents, and the effectiveness of implementation. An audit should not be confused with surveillance or inspection activities performed for the sole purpose of process control or product acceptance.

Competent Person – One that is capable of identifying existing or predictable hazards in the surrounding working conditions which are unsanitary, hazardous, or dangerous to employee’s, and who has authority to take prompt corrective measures to eliminate them.

Contractor Quality Control Plan (CQCP) - A document that describes the management system for planning, performing, and assessing work to ensure that the results demonstrate stated quality, technical, and performance objectives. The CQCP will describe the organizational structure, quality control policies and procedures, functional responsibilities, levels of accountability and authority, and necessary interfaces for organizations performing activities in support of the program management office.

Control – A standard of comparison for verifying or checking the “Findings" of an experiment;

specifically, such a standard obtained by withholding the substance, treatment, drug, etc being tested. To check or verify test results.

Controlled Documents - Documents that have been assigned a unique identifier and issued to a specific person, organization, or facility and which represent the current accurate and complete version of the subject matter. These documents are maintained current by providing revisions to holders on a controlled list. Changes are subject to a review and approval process.

Corrective Action - Measures taken to rectify deviant conditions and, when necessary, to preclude repetition or recurrence.

Terms and Definitions (continued)

Deficiency – During the implementation of a procedure or standard, the quality of an item is found to be unacceptable or indeterminate with respect to project criteria. Examples of Deficiencies include, but are not limited to, test failures, physical defects, incorrect or inadequate documentation, data losses, deviation from prescribed processing, inspection, or procedures.

Definable Feature of Work – Task that is separate and distinct from other tasks and has separate control requirements. Different trades or disciplines could identify it, or it could be work by the same trade in a different environment.

Deliverable - A document, report, study, information, sample or other item required by the task order scope of work or specification to be submitted to the Government. Deliverables are usually listed on a Submittal Register, Engineering Form 4288.

Derived Concentration Guideline – A derived radionuclide-specific activity concentration within a survey unit corresponding to the release criteria. DCGLs are derived from activity / dose relationships through various exposure pathway scenarios.

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

Field Work Variance - An identified deviation from approved plans, drawings or specifications.

Field Work Variance Approval - Documented authorization from the Contracting Officer or Contracting Officer Representative to depart from specified requirements.

Finding - An identified noncompliance or deviation from established requirements.

Inspection - Examination or measurement to verify whether an item or activity conforms to specific requirements. It is ongoing or “after the fact”. The objective of inspection is to ensure that the work is accomplished in accordance with contract provisions.

Inspector - A qualified person who performs inspection activities to verify conformance to specific requirements.

Item - An all-inclusive term used in place of any of the following: object, facility, sample, assembly, component, equipment, material, module, part, structure, subassembly, subsystem, system, unit, documented concepts, or date.

Nonconformance - A deficiency in implementation of a procedure or standard which renders the quality of an item unacceptable or indeterminate with respect to project criteria. Examples of nonconformance include, but are not limited to: test failures, physical defects, incorrect or inadequate documentation, data losses, or deviation from prescribed processing, inspection, or procedures.

Observation - A statement of fact regarding the potential for noncompliance, which could lead to a more serious problem if not identified and/or corrected, but which does not constitute a lack of compliance with established requirements.

Procedure - A document that specifies or describes how an activity is to be performed.

Qualification (Personnel) - The characteristics or abilities gained through education, training, and/or experience, as measured against established requirements, such as standards, tests and/or evaluation that relate to the ability of a person to perform a required function.

Quality – Quality is providing a safe, sound, reliable and functional product that can be economically designed, constructed, and operated and meets the requirements of the approved plans and specifications.

Quality Assurance – A program for the systematic monitoring and evaluation of the various aspects of a project, service, or facility to ensure that standards of quality are being met.

Quality Assurance Audit Team – Two or more Quality Assurance personnel who are responsible for audit performance and reporting.

Quality Control - A system for verifying and maintaining a desired level of quality in a product or process by careful planning, use of proper equipment, continued inspection, and corrective action as required.

Quality Control Program - The overall program established by an organization to implement the requirements of the contract document. The program assigns responsibilities and authorities, defines policies and requirements, and provides for the performance and assessment of work.

The Quality Control Program is described in the CQCP.

Quality Control Record - A completed document that furnishes evidence of the quality of items and/or activities affecting quality.

Receiving - Taking delivery of an item at a designated location. Receiving does not constitute "acceptance" of the item.

Repair - The process of restoring a nonconforming characteristic to a condition such that the capability of an item to function reliably and safely is unimpaired, even though that item may not conform to the original requirement.

Rework - The process by which an item is made to conform to original requirements by completion or correction.

Sampling and Analysis Guide - Document that provides a single source document to guide sampling and analysis. It also provides a compendium of procedures, protocols, and methodologies, which may be used in preparing Site Specific Work Descriptions (WDs).

Standard Operating Procedure - An approved document that details an operation, responsibilities, analysis, process, or action whose mechanisms are thoroughly prescribed and that is commonly accepted as the method for performing certain routine or repetitive tasks.

Standard Quality Procedure - A set of implementing procedures which establish the responsibilities and describe the methods of performing quality-affecting activities in response to the CQCP requirements.

Surveillance - The act of monitoring or observing to verify whether an item or activity conforms to specified requirements.

Training - To impart specific information with regard to job functions, which will achieve initial proficiency, maintain proficiency and adapt to changes in technology, methods or job functions.

1.0 Formally Utilized Sites Remedial Action Program

1.1 Background

During World War II, the nation began a top-secret project to build the first atomic bomb. The Army created the Manhattan Engineer District (MED) to carry out much of the work of the so-called “Manhattan Project” during World War II. After the war, the nation sought ways to use nuclear energy for peaceful purposes and formed the Atomic Energy Commission (AEC) in 1946. Some of this work was performed in the St. Louis, MO area.

From 1942 to 1957, the MED/AEC contracted with Destrehan Street Refinery and Metal Plant (later Mallinckrodt Chemical Works) to process natural uranium, producing uranium oxide, trioxide and metal uranium. This became the St. Louis Downtown Site (SLDS).

In 1946, MED acquired the St. Louis Airport Site (SLAPS), an approximately 22 - acre site just north of the St. Louis Airport for storage of residues and other material from the downtown site.

In subsequent years, adjacent properties became contaminated as a result of erosion.

In 1966, a private company purchased SLAPS residues, which contained valuable metals, and began hauling them to a site on Latty Avenue in Berkeley, MO, after which they were sold for their commercial value. Later, the material as sold again and much of it shipped to Colorado.

Surveys in 1977 showed that the former owners had left contamination on the Latty Avenue Property. Part of this site was later called the Hazelwood Interim Storage Site (HISS).

In addition, transport and migration of the material spread contamination along the haul routes to nearby Vicinity Properties. Although the federal government was not responsible for this contamination, Congress directed that the government add these sites to the Formally Utilized Sites Removal Action Program (FUSRAP).

On October 4, 1989, SLAPS and HISS were added to the Environmental Protection Agency’s National Priorities List (NPL).

Refer to Figure A – 1 in Appendix A for the location of SLAPS, SLDS, and HISS.

1.2 Site History

Each of the separate locations that make up the St. Louis FUSRAP Sites and IAAAP is discussed further in the following subsections.

1.2.1 SLDS

The SLDS is located in an industrial area on the eastern border of the City of St. Louis, 300 Feet west of the Mississippi River and 2 miles north of the downtown area. The site is compromised of a large chemical-manufacturing complex owned and operated by Mallinckrodt Chemical Works (Mallinckrodt), plus adjacent commercial and city-owned vicinity properties (VPs).

Manufacturing plants, support facilities, and administrative buildings cover a large portion of the 45-acre site, with much of the remaining site covered with asphalt or concrete. The site is bounded by an earthen levee to the east, which protects the area from Mississippi River floodwaters, Dock Street to the south, North 9th to the west, and Bremen Street to the north.

Additional properties were added to the site boundary by the March 31, 2005 Non-Significant Change to the St. Louis Downtown Site Record of Decision (SLDS ROD). The USACE and Remedial Action Contractor (RAC) support zone complex for the project is located at One Angelrodt Street, St. Louis, MO 63147.

Mallinckrodt has operated a chemical facility continuously since 1867. From 1942 to 1957, MED and its successor, the AEC contracted Mallinckrodt, to process uranium ore for the production of uranium metal. Residuals of the process, including spent pitchblende ore, process chemicals, and radium, thorium, and uranium, were inadvertently released from the Mallinckrodt facility and into the environment through handling and disposal practices. Residuals from the uranium process had elevated levels of radioactive radium, thorium, and uranium. As a result of characterization of the soil, ground water, surface water, sediment, air, and structures associated with the site, radiological contamination was determined to be present in surface and subsurface soils and groundwater, including inaccessible soils under buildings, roads, and railroads.

There are 37 VPs associated with the SLDS to date as shown on Figure A-6 in Appendix A.

These sites are under various degrees of investigation and remedial action that ranges from Pre- Design Investigation (PDI) to Final Status Survey Evaluations (FSSE).

During this process, several characterization studies have been performed by the Department of Energy (DOE) in 1990, 1991, and 1995. The results of these studies identified uranium (processed natural uranium) thorium-230 (Th-230), radum-226 (Ra-226), and thorium-232 (Th- 232 as major radiological contaminants. Although relative ratios of these radionuclides vary by specific location, with some exceptions uranium is the predominant radioactive material present at the SLDS. Smaller, although potentially significant, quantities of members of the naturally occurring actinium decay series have also been reported in some samples

The depth of contaminated soil varies. Most of the contamination is in the upper 3 to 6 feet of soil. However, at some locations contamination extends as deep as 16 feet. Subsurface characterization data for inaccessible soils (e.g., beneath buildings), at the SLDS VPs is limited.

These inaccessible soils are to be addressed under a separate ROD and will not be remediated at this time.

1.2.2 North St. Louis County Sites

The North St. Louis County sites consist of the following location names, properties, and groupings

• SLAPS - specifically, those portions of Investigation Areas (IAs) 1 through 7 still to be remediated as of September 2, 2005, the effective date of the ROD (USACE, 2005); includes the southern portions of IAs 5 through 7 along the southern boundary of the SLAPS adjacent to the Norfolk-Southern railroad

• SLAPS VPs

− IAs 8 through 13

− Haul Roads – Eva Avenue, Frost Avenue, Hazelwood Avenue, McDonnell Boulevard, and Pershall Road

− Haul Road Properties – VPs 1 through 63

− Coldwater Creek

− Coldwater Creek VPs 1C through 10C

− St. Cin Park, Duchesne Park

• Latty Avenue Properties

− HISS

− Futura Coatings Company

− Latty Avenue VPs 1L through 6L

− VPs 40A and 10K530087

Figure A-3, in Appendix A, shows the location of the North County Sites. The potential radiological contaminants at the North St. Louis County Sites are members of the naturally occurring uranium, thorium, and actinium decay series. The predominant contaminant is Th- 230, a member of the uranium decay series. Decay products of Th-230 (Ra-223 and progeny) are also present but at much lower concentrations. However, the relative concentrations of the Ra-226 and progeny will increase with time, due to radioactive ingrowth.

Non-radiological (chemical) contaminants may also be present at these sites. However, the risk due to radiological materials tends to be an order of magnitude or greater than risks associated from chemicals. Because some chemicals have been identified as potential Contaminants of Concern at the SLAPS, they are considered in the final survey design for the VPs.

1.2.2.1 SLAPS

The SLAPS is located in an unincorporated 21.7 acre property in north St. Louis County owned by the City of St. Louis. The SLAPS is bound by McDonnell Boulevard on the north, Banshee Road and the Norfolk Southern Railroad on the South, and Coldwater Creek on the west as shown in A-3 of Appendix A. Figure A-2 depicts an aerial photo of the subject property. There are no permanent sewer lines or overhead utility lines within the security fence of the SLAPS, however, utilities are located parallel to McDonnell Boulevard. The support zone is located at 110 McDonnell Boulevard, Hazelwood, MO 63042.

From 1946 to 1966, SLAPS was used to store MED/AEC residue materials generated by uranium separation processes at Mallinckrodt. The process residues included solids from the neutralization and filtration of ore raffinate, which was stored on the ground, and radium–bearing residues that were stored in drums. Barium cake residues were also stored on the ground at the site. Other wastes brought to SLAPS included used dolomite liners and recycled magnesium fluoride liners; tailings from a process to recover uranium from magnesium fluoride slag; 50,000 empty drums, 3,500 tons of uranium-containing sand; and radioactive scrap metal. Some of these materials were buried in earthen pits onsite.

The SLAPS was completed in Fiscal Year (FY) 2007. A close-out ceremony was held on May 30, 2007.

1.2.2.2 SLAPS VPs

The SLAPS VPs consist of approximately 78 properties including properties along former haul routes between the SLAPS and the HISS, Coldwater Creek, the open fields (former ballfield area) immediately north of the SLAPS and other SLAPS contiguous properties. The impacted properties are located along haul routes between the SLAPS and the HISS. These haul routes include Eva Avenue, Frost Avenue, Hazelwood Avenue, McDonnell Boulevard, and Pershall Road. The SLAPS VPs are primarily located within the City of Berkeley; however, Pershall Road, the north side of McDonnell Boulevard, and a portion of Hazelwood Avenue are within the City of Hazelwood. Coldwater Creek flows for 500 feet (ft) along the western border of the

SLAPS. The creek originates 3.6 miles (mi) to the south of the SLAPS and continues for 15 mi in a northeasterly direction through the City of Hazelwood, the City of Florissant, unincorporated areas of St. Louis County, and along the northern edge of the community of Black Jack, until it discharges into the Missouri River. The creek, except for 1.2 mi under the Lambert –St. Louis International Airport, is generally accessible to the public. The contiguous properties surrounding the SLAPS were designated as Investigation Areas (IAs) 8 through 13. These properties are located within the City of Hazelwood, the City of Berkeley, the airfield owned buy the City of St. Louis, and on property controlled by the Boeing Company and GKN Aerospace Services.

In 1982, a radiological characterization of the ditches to the north and south of SLAPS and portions of Coldwater Creek indicated radioactivity levels exceeding DOE guidelines then in effect. A radiological characterization of the SLAPS was subsequently conducted in 1986 to 1990 to further define the extent of radioactive contamination and to evaluate possible remediation alternatives.

1.2.2.3 Latty Avenue Properties

The Latty Avenue Properties include HISS, Futura Coatings Company, and eight VPs designated as 1(L) through 6(L), 40A, and 10k530087. The majority of the VPs are located along Latty Avenue. The Latty Avenue Properties are 0.7 mi northeast of the SLAPS. The HISS and Futura Coatings Company, located at 9170 and 9200 Latty Avenue (respectively) cover an 11 acre tract of land and are in the City of Hazelwood. The VPs are located predominately within the City of Berkeley.

The topography of the site is relatively flat; the majority of the property is within the 100-year floodplain of Coldwater Creek. The elevation of HISS ranges from approximately 510 to 530 feet (ft) above mean sea level (msl), and its land surface ranges lie 15 to 20 ft above Coldwater Creek. The 100-year floodplain at HISS is established at 520 ft above msl.

In 1966, the federal government sold the uranium-bearing residues at SLAPS to Continental Mining and Milling Company. Then, in 1967, Continental Mining and Milling Company moved the material from SLAPS to another site at 9200 Latty Avenue in Hazelwood, MO for later shipment to Canon City, Colorado.

In 1979, the property owner stocked piled approximately 13,000 cubic yards (cy) from the western half of the property to construct a manufacturing facility (Futura Coatings, CO). The material was stockpiled on the eastern half of the property and designated as the Main HISS Storage Pile. In 1988, soils were excavated for construction of a railroad spur into the site and stockpiled in two separate areas on the property (Railroad Spoils Piles A and B). These piles were subsequently removed, transported, and disposed under the direction of the USACE in the spring of 2000. An aerial photo of the HISS, before the stockpiles were removed can be found in Appendix A, Figure A-4.

In October 2001, the remaining above ground low level radioactive waste material was loaded into gondola rail cars, transported, and disposed of at a USACE pre-approved Low Level Radioactive Waste landfill.

2.0 Purpose and Scope

This Quality Assurance Program Plan (QAPP) was developed as a sitewide plan for Quality Assurance (QA) activities for and with input from the USACE MVS.

The FUSRAP Sitewide QAPP will address the overall QA operations as they relate to the QA contractor and their involvement with the USACE MVS FUSRAP. This QA process will assist the USACE in reaching their objectives at all FUSRAP sites. These objectives are as follows:

• All work plans and work descriptions are implemented as approved by the USACE.

• Protect human health and the environment.

• Execute the approved alternative for cleaning up radioactive contamination above health-based cleanup guidelines (RGs).

• Minimize adverse effects on area business operations.

• At the conclusion of each FUSRAP site, assure that the RAC turns over required documentation to the USACE.

This FUSRAP Sitewide QAPP is intended to assist the USACE by providing guidance in the performance of QA operations for the fiscal year 2007 and beyond. In addition, this plan is intended to replace the previous Site Specific QAPPs for SLAPS and SLDS. This will include, but is not limited to, responsibilities, training, pre-award activities, testing and documentation.

2.1 Specific FUSRAP Sitewide QAPP Items

The following subsections discuss the procedure for reviewing and revising this QAPP. In addition, the duration and applicability of the QAPP are addressed.

2.1.1 QA Plan Review Process

The FUSRAP Sitewide QAPP will be reviewed and amended, as needed, but at least once each calendar year. This review process will at a minimum involve the Area Engineer and the QA Contractor Quality Assurance Representatives (QAR). This review process will involve, but is not limited to, a review of the existing workload and Delivery Orders (DO), and compare each to future FUSRAP needs. This review process will then extend to this QAPP and a determination will be made if the document requires revision.

2.1.2 Period Covered

This QAPP is considered a living and working document that will be in effect for the duration of the USACE MVS FUSRAP or until the USACE rescinds said document.

2.1.3 Applicability

This QAPP applies to all personnel, including contractors and consultants having responsibility for construction quality oversight on FUSRAP, under the jurisdiction of the USACE MVS Office and NWK Office.

The QAPP will incorporate independent assessment tools to evaluate the performance of FUSRAP site activities in relation to the requirements of this plan and applicable USACE operating procedures and instructions. This plan, together with the contractors’ site-specific procedures and instructions, forms an integrated management control system for conducting FUSRAP sitewide activities in a manner that will assure compliance with specified standards, personnel safety, and the protection of the environment. The significant features of this QAPP are:

• Quality verification and oversight activities that demonstrate the completeness and appropriateness of achieved quality.

• Assurance that activities are performed and documented to specified requirements.

3.0 Staffing

Each FUSRAP site will be staffed with at least one Alternate Contracting Officer’s Representative (ACOR) and one QAR. The FUSRAP Area Engineer will provide assistance with engineering, administrative assistance, and technical support as needed.

The QA staffing is dependent on the value, complexity, and geographic location to the contract being administered, to provide flexibility and Government satisfaction to the USACE MVS. The FUSRAP Area Engineer directly administers the QA contracts. It is the responsibility of the FUSRAP Area Engineer, through MVS QA personnel or a construction service contract to ensure adequate QA personnel are available to properly cover all construction contract work.

3.1 Job Responsibilities

QA is the process by which the Government assures end product quality. Pre-Award and Post- Award activities successfully performed by QA Personnel assures an effective Quality Assurance Program.

3.1.1 USACE FUSRAP Area Engineer

The Area Engineer for the FUSRAP Area Office is also designated as the Contracting Officer’s Representative (COR). The Area Engineer has been assigned the responsibility of managing activities related to the remediation of the FUSRAP sites in the St. Louis District.

Responsibilities may include, but are not limited to:

• Serves as technical advisor to the Project Manager in the areas of Environmental Protection Agency (EPA) coordination, disposal site strategy, and special environmental, health, and safety considerations.

• Oversees ongoing and projected remediation activities, contractor operations and field investigations.

• Coordinates all field remediation activities to accomplish reporting requirements.

• Assures monitoring and surveillance activities are performed.

• Participates in the work and provides leadership, coaching and problem solving assistance to FUSRAP workforce.

• Integrates work processes and products, obtains resources, and serves as liaison with the Branch Chief. The accountability for the timely delivery of quality products and services produced by the team rests with the Area Engineer.

3.1.2 USACE FUSRAP ACOR

The ACOR works under general supervision of the Area Engineer. The ACOR is responsible for construction QA and contract administration activities on assigned construction projects.

Responsibilities may include, but are not limited to:

• Oversees construction and remedial action activities associated with cleanup of the FUSRAP sites.

• Ensures that contract work, materials, etc. are in strict compliance with plans, drawings, specifications and task orders.

• Makes recommendations concerning interpretation of the task orders, specifications, proper payment of contractors and approval of plans and shop drawings.

• Coordinates accomplishment of construction work and resolution of construction problems with other elements as necessary.

• Oversees all matters pertaining to safety.

• Prepares technical information and assistance for negotiation of contract modification and task orders.

3.1.3 USACE FUSRAP Office Engineer

The Office Engineer works under the general supervision of the Area Engineer. The Office Engineer is responsible for construction QA and contract administration activities on assigned construction projects. Responsibilities may include, but are not limited to:

• Oversees construction and remedial action activities associated with cleanup of the FUSRAP sites.

• Oversees all matters pertaining to safety.

• Prepares technical information and assistance for negotiation of contract modifications.

• Reviews public vouchers (SF1034), conducts labor interviews, checks payrolls for compliance with Davis-Bacon, and prepares memos and monthly status reports.

• Sets up and maintains the contract files.

• Assists in establishing Area Office Standard Operating Procedures (SOPs).

• Maintains a good working relationship with outside agencies, contractors, District

Staff, Governments and local sponsors.

• Keeps the Area Engineer and ACOR informed of technical and administrative problems.

3.1.4 USACE FUSRAP Construction Representative

The Construction Representative works under general supervision of the COR, in monitoring and controlling construction operations. Responsibilities may include, but are not limited to:

• Assures effective Contractor Quality Control (CQC) and QA on construction projects.

• Reviews for acceptability contractors various proposed plans, procedures, equipment, materials and sources of supply.

• Ensures that proper safety practices are implemented and enforced.

• Checks contractor's payrolls for compliance with wage rates and labor provisions of the contract.

• Conducts labor interviews.

• Prepares Daily Logs of Construction, Safety Reports, and quantity reports.

• Computes and verifies quantity estimates for partial and final progress payments.

• Provides monthly progress photographs of various features of the contract work.

• Reviews final as-builts, shop drawings and final survey/quantity reports.

3.1.5 Construction Contractor Supplied Personnel

A construction contractor may provide either a Quality Assurance Representative III (QAR III) or a Civil Engineering Technician (CET) to provide the USACE with QA support and oversight on environmental and construction projects. These positions vary by the level of experience only.

3.1.5.1 Construction Management Services

The QAR III or CET shall be assigned duties associated with construction management.

Responsibilities may include, but are not limited to:

• Assist in analyzing projects, which include developing functional requirements, project definitions, defining reporting requirements, and ensuring that the project plans are consistent with Government requirements.

• Review health and safety plans, plans of operation, work plans, fire protection plans, and industrial hygiene plans. These reviews will be from bid, construction, operational, and environmental points of view.

• Review technical documents and submittals for completeness, technical adequacy and compliance with contract requirements and applicable statutes and regulations as they relate to closure reports.

Each QAR III or CET will observe and inspect field construction to verify that the work is in conformance with the contract requirements, while identifying, documenting, and working with the contractor to assure corrective actions are put in place regarding health and safety hazards.

Participate in QC inspections on selected construction contracts, becoming familiar with all phases of the contractor quality control system and assist field personnel in the performance of their QC duties. The percentage of involvement will be directed by the Government contact. In addition, each QAR III or CET may provide general management staff assistance on environmental, operations, and maintenance projects, including attending meetings, preparing meeting reports, preparing briefings, and performing other such functions as required.

3.1.5.2 Environmental Services

The QAR III or CET shall be assigned duties associated with environmental services.

Responsibilities may include, but are not limited to:

• Review plans and specifications for new construction projects to adequately provide coverage of relevant environmental laws.

• Maintain an open line of communication between the Government and contractor while actively participating in the partnering process.

• Assist in the inspection, evaluation and reporting of special environmental problems and issues that may occur on construction contracts.

• Assist in the preparation and review of documentation or reports required by local, state and federal agencies related to construction contracts.

• Review hazardous waste manifests in accordance with all federal and state regulations.

3.2 Organizational Structure

The organization established for implementation of the FUSRAP QAPP is structured such that the contractor performing the work is responsible for achieving and maintaining quality. The FUSRAP Area Office is responsible for assuring overall quality and verifying quality achievement. The USACE Construction Organization Chart is shown in Figure 3-1.

4.0 Pre-construction Conference

As directed by the USACE, each QAR will attend their site’s Pre-construction Conference that will be held as soon as possible after a site contract has been awarded and prior to the commencement of any physical work. The objective of each Pre-Construction Conference will be to review the contract clauses to include accident prevention, personnel requirements, and procedural matters. This conference is extremely important because it establishes the ground rules for administering the contract. Due to the importance of QA/QC, these topics may be discussed at a separate meeting. The degree of QA/QC related discussions depend largely on the scope and magnitude of the contract and on the individuals from each organization that are present.

The Area Engineer may request the QAR to take detailed minutes of the conference and provide copies to all participants, as well as address quality issues from a QA perspective.

5.0 QA during Design

The QA Program ensures that a thorough design review is performed and a functional design is developed without obvious or repetitive design deficiencies.

5.1 Scheduling of Projects

During the design of a project, the Area Engineer and his staff will monitor the scheduling and progress of the design to ensure a timely issuance of the construction contracts. The projected construction time and dates will be examined for their impact on related projects, anticipated manpower, and flow of construction work and suitable weather. The Area Engineer will advise the Construction Branch of the most advantageous date for the issuance of a construction contract.

5.2 Construction Reviews

A construction review will be performed for each project and will follow the guidelines of ER 415-1-11. The designs will be reviewed for practicality and ease of construction, which requires using standard and/or common construction practices and equipment whenever possible. The suitability of the project to the existing field conditions and future uses will also be examined.

The material requirements of each project will be reviewed for quality, availability and suitability. A general review of the plans and specifications will be performed to ensure that they can be understood, administered, and enforced. All designs will be examined for errors, omissions or ambiguities and compared to similar completed projects. The comparison should bring forth techniques and/or materials successfully used on previous projects or design deficiencies to be avoided. As directed by the USACE, review and provide comments on work plans and descriptions that have been developed by the RAC and submitted to the USACE for approval.

5.3 Bid Reviews

A Bid Review, if applicable (i.e. cost contracts) will be performed for each project and will follow the guidelines of ER 415-1-11. The ease of developing a bid from the design and facilitating progress payments will be considered during the review. Each bid item will be examined to determine how it functions (best as a lump sum item or a unit price item.) When examining bid items the potential accuracy of the quantity take-offs and field measurements will be assessed along with the comparative size of the bid items to the contract, plus the necessity to split bid items into an A and B item. The ambiguity and amount of risk placed in the contract will be considered and, when possible, alternatives suggested minimizing their affect on bids.

5.4 QA Reporting and Testing

QA Reporting and Testing will be performed in accordance with contract specifications, only when directed by the USACE, and under any of the following circumstances:

• When items are identified that require special testing, documentation or certification for any phase of work that require an inspection by the manufacturer’s representative.

• When the submittal register requires review to document the inclusion of plans and/or materials that are critical to the project.

• In the event that materials used in construction appear not to meet the contract requirements, testing is necessary to verify.

• When CQC test results indicate failure and the contractor is reluctant to correct the areas that have failed.

• If the Area Engineer is provided evidence that the results of CQC testing are fraudulent, inaccurate, or when the materials being used are obviously unsuitable or contrary to any test results.

• When deemed necessary by the Area Engineer in order to ensure a quality product.

Should the USACE request the QA Contractor to perform a QA Audit/Surveillance on a particular RAC field testing procedure, utilizing instrumentation provided by the USACE, the QA Contractor must provide documentation to the USACE that the QAR, if required, is currently certified to perform the test. These tests may be, but are not limited to, ASTM Method C 143 - Slump of Hydraulic Cement Concrete, ASTM Standard C 172 – Sampling Freshly Mixed Concrete. Each proof of certification must be accompanied with documentation that the QA Contractor personnel possesses adequate knowledge to:

• Perform instrumentation calibration

• Interpret calibration records

• Interpret each reading produced by the USACE and / or RAC instrumentation

• Document the required parameters for the test area was met or re-work was required

• Report the findings to the USACE

6.0 QA during Construction

The Quality Assurance surveillance activities by each FUSRAP QAR will be focused on, but not limited to, verifying the effectiveness of the RAC Quality Control System. This is achieved by utilizing the following procedures on each construction contract.

6.1 Quality Assurance Activities

Quality assurance activities are, but not limited to, the following:

• Prior to award of the contract, the COR and his staff shall review the contract documents and assess the requirements needed for an effective CQCP.

• During the Pre-construction Conference, the Area Engineer shall address the requirements of an effective CQCP.

• The Area Engineer and his staff shall review the submitted CQCP to ensure it is adequate and conforms to the requirements of the contract documents. The CQCP must be submitted and approved prior to the contractor commencing on site work.

• A coordination meeting will be held to discuss QA/QC responsibilities and requirements in detail.

• During construction, a Daily Quality Assurance Report (DQAR) shall be prepared daily, from the date following the Notice to Proceed (NTP) until the project is accepted from the contractor by the USACE. Additional information on this subject can be found in Section 8.0.

• The ACOR will ensure that the Submittal Register (ENG FORM 4288) is submitted within 15 days after the NTP. The ACOR will review and recommend approval of the Submittal Register to the Area Engineer. The approved Submittal Register should be reviewed by the QAR and the ACOR twice a month, to assure that all required submissions are made on a timely basis.

• Each QAR will participate in the USACE Three-Phase Inspection System (Section 7.2) for each Definable Feature of Work (DFW) at their site.

• An example list of QAR Duties may be found in Figure 6-1. The Figure is provided for guidance only as the duties of the QAR evolve over time.

6.2 Three-Phase Inspection system

The three-phase inspection system will be used to ensure contractor compliance with the plans and specifications. The function of each QAR is to assure that the following inspections are completed as required for each DFW.

The three phases are Preparatory Inspection Phase, Initial Inspection Phase and Follow-up Inspection Phase. Each control phase provides the opportunity to prevent problems and deficiencies. Generally, construction knowledge and experience, although necessary, will not get the job done. The contractor’s CQCM must know in detail the requirements of the specific contract. The role of the USACE is to see that the control phases are thoroughly and timely performed and conducted by the contractor’s designated CQCM and that the CQCM is knowledgeable and adequately performs the necessary control.

6.2.1 Preparatory Inspection

A Preparatory Inspection is a systematic, documented review of the readiness for startup or continued extended use of a facility, process, or activity. Preparatory inspections are typically conducted before proceeding beyond project milestones and prior to institution of major phase of work activities.

This phase shall be performed prior to beginning work on each DFW; after all required plans/documents/materials are approved/accepted, and after copies are at the work site. This phase shall include:

• A review of each paragraph of applicable specifications, reference codes, and standards. A copy of those sections of referenced codes and standards applicable to that portion of the work to be accomplished in the field shall be made available by the Contractor at the Preparatory Inspection. At the conclusion of this phase, these copies shall be maintained in the field, either electronically or paper copy, and available for use by the Government personnel until final acceptance of the work.

• A review of contract drawings

• A check to assure that all materials and/or equipment have been tested, submitted, and approved.

• A check to assure that provisions have been made to provide required control inspection and testing.

• Examination of the work area to assure that all required preliminary work has been completed and is in compliance with the contract and work plans.

• A physical examination of required materials, equipment, and sample work to assure that they are on hand, conform to approved shop drawings or submitted data, and are properly stored.

• Reviews of each Activity Hazard Analysis (AHA) to assure safety requirements are properly addressed.

• Discussion of procedures, including repetitive deficiencies, for constructing the work.

Document construction tolerances and workmanship standards for that phase of the work.

• A check to ensure that the portion of the CQCP for the work to be performed has been accepted by the Contracting Officer (or the designated representative).

Notification to the USACE at least 48 hours prior to the initiation of any DWF to schedule the date and time of the Preparatory Inspection, unless waived by the USACE. This phase shall include a meeting conducted by the CQCM, and attended by the USACE, QAR, Property Owner Representative, RAC superintendent, other CQC personnel (as applicable), and the foreman responsible for the DFW. The results of the preparatory phase actions shall be documented by separate minutes prepared by the CQCM and placed in the project files. The Contractor shall instruct applicable workers as to the acceptable level of workmanship required in meeting contract specifications. It is not the responsibility of the QAR to complete any of the paper work for a Preparatory Inspection. The QAR’s main responsibility is to document that all required areas of each DFW are addressed in each Preparatory Inspection chaired by the CQCM or designee.

6.2.2 Initial Inspection

An Initial inspection must be accomplished at the beginning of a DFW. The Initial Inspection will verify that control for the work developed in the Preparatory Inspection is implemented and the work is being performed to at the level of workmanship mutually agreed upon. Here is the best opportunity to get the work off to a proper start in full compliance with contract requirements. This is the time for the contractor to establish standards of workmanship. If there are differences of opinions in the interpretation of contract requirements, the issue can be discussed and settled at the onset of work much easier than after the work is in place. The Initial Inspection is a practical method of performing preventive inspection and reaching agreements in advance.

This phase shall be accomplished at the beginning of a DFW. The following shall be accomplished:

• A checklist of preliminary work to ensure that it is in compliance with contract requirements. (Review minutes of the preparatory meeting.)

• Verification of full contract compliance. Verify required control inspections and testing.

• Establish level of workmanship and verify that it meets minimum acceptable workmanship standards.

• Resolve all differences.

• Check safety to include compliance with the safety plan and AHA. Review the activity analysis with each worker.

Separate minutes of this phase shall be prepared by the CQCM and placed in the project files.

Exact locations of initial phase shall be indicated for future reference and comparison with follow-up phases. The initial phase shall be repeated for each new crew to work on-site, or any time acceptable specified quality standards are not being met. It is the responsibility of the RAC CQCM to complete each Initial Phase form properly. The major responsibility of the QAR during each Initial Phase is to document that all required items that were addressed in each Preparatory Inspection, are adequately in place to start the DFW.