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PROJECT QUALITY ASSURANCE PLAN (PQAP) for GREEN LINE EXTENSION PROJECT December 9, 2011 Glx_Mbta Pqap_Rev 0 (120911)

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PROJECT QUALITY ASSURANCE PLAN (PQAP) for

GREEN LINE EXTENSION PROJECT

December 9, 2011

Glx_Mbta Pqap_Rev 0 (120911)

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

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December 9December 9, 2011

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

HISTORY OF REVISIONS

REV. REVISION AFFECTED

NO. DATE SECTIONS COMMENTS

Rev. 0 December 9, 2011

- i - December 9, 2011

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

MISSION STATEMENT

The Massachusetts Bay Transportation Authority (MBTA) and the Massachusetts Department of Transportation (MassDOT) are committed to the implementation of a Project Quality Assurance Plan (PQAP) for the development of the Green Line Extension Project that meets the requirements of the U.S. Department of Transportation Quality Assurance/Quality Control Guidelines, FTA-IT-90-5001-02.1.

MassDOT is the current proponent for the planning phase of the Green Line Extension Project. The MBTA, with MassDOT’s support, will manage the preliminary engineering, final design and construction phases of the project. For the preliminary engineering phase, the MBTA will manage development of preliminary design plans and bid package materials to support procurement of a Design-Build contractor. MassDOT will continue to provide oversight on the project as the design-build contract moves forward, and will also help to ensure robust public outreach during the preliminary engineering, final design and construction phases of the project. The MBTA will be the operating agency and ultimate owner of the Green Line Extension. MassDOT will be fully responsible for funding the construction and incremental operating costs for the project. MassDOT will adopt the MBTA’s design, safety and quality assurance guidelines.

The PQAP is applied to the Green Line Extension Project and will evolve as the project progresses to eventually cover all capital contract work from development of specifications through project completion. The plan will assure compliance with all requisite contract documents, codes and standards during the preliminary design, final design, construction and test phases of the project. The plan assures that completion of the Program Management/Construction Management (PM/CM) Consultant’s and the Design-Build contractor’s work are verified and documented in accordance with the PQAP and applicable procedures and that the contracts lead to safe, on-time and cost effective transit service. All supporting documents for this plan and other consultants’ and contractors’ quality assurance programs, are controlled, maintained current, and are readily available to all employees conducting work governed by the PQAP. The plan will be reviewed by appropriate MBTA staff at least annually and maintained to ensure that relevant processes, products, and services meet the established technical requirements.

The plan will ensure that designs are in accordance with the MBTA’s engineering requirements. Following the plan will allow for early detection and correction of potential problems, minimize costs and prevent delays. It will also set standards for testing equipment during development, manufacturing and installation. The plan includes a uniform system of documentation that allows easy access for audit and evaluation of adherence to the plan for specific task(s). The plan is integral to the MBTA’s and MassDOT’s commitment to improve efficiency, quality, service and management system-wide. The plan is also critical to the development of a management environment that produces excellence and accountability. Use and implementation

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

of this PQAP will enable the MBTA and MassDOT to meet the present and future transportation needs of the Commonwealth.

Jack Donovan MBTA Deputy Director

of Design and Construction, Quality Assurance

Mary R. Ainsley MBTA Program Manager

and Director of Design and Construction – Green Line

Katherine S. Fichter MassDOT Program Manager Green Line Extension Project

Manager of Long Range Planning

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

HISTORY OF REVISIONS ............................................................................................................ i

MISSION STATEMENT .............................................................................................................. iii

1.0 MANAGEMENT RESPONSIBILITY................................................................... 1

2.0 DOCUMENTED QUALITY MANAGEMENT SYSTEM ................................... 9

3.0 DESIGN CONTROL............................................................................................ 12

4.0 DOCUMENT CONTROL.................................................................................... 14

5.0 PURCHASING..................................................................................................... 16

6.0 PRODUCT IDENTIFICATION AND TRACEABILITY ................................... 18

7.0 PROCESS CONTROL ......................................................................................... 20

8.0 INSPECTION AND TESTING............................................................................ 21

9.0 INSPECTION, MEASURING, AND TEST EQUIPMENT ................................ 23

10.0 INSPECTION AND TEST STATUS................................................................... 25

11.0 NONCONFORMANCES..................................................................................... 26

12.0 CORRECTIVE ACTION ..................................................................................... 28

13.0 QUALITY RECORDS ......................................................................................... 29

14.0 QUALITY AUDITS ............................................................................................. 31

15.0 TRAINING ........................................................................................................... 33

LIST OF FIGURES

FIGURE 1 – MBTA/MASSDOT GREEN LINE EXTENSION PROJECT ORG. CHART 6

FIGURE 2 – PM/CM ORGANIZATION CHART 7

FIGURE 3 – GREEN LINE EXTENSION PROJECT ORGANIZATION CHART 8

FIGURE 4 – QUALITY ASSURANCE PLAN DOCUMENT PRECEDENCE 11

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

1.0 MANAGEMENT RESPONSIBILITY

Purpose

Section 1 of this PQAM establishes quality requirements, responsibilities and procedures for Management Responsibility, Element 1 of the FTA’s QA/QC Guidelines.

1.1 The MBTA/MassDOT management team is responsible for establishing and demonstrating the MBTA/MassDOT commitment to quality as stated in the Mission Statement. The MBTA/MassDOT management team is charged with ensuring that the Quality Policy is understood, implemented and maintained throughout all appropriate levels of design and construction and used by other Departments that participate in project activities.

1.2 This PQAP provides specific requirements for project implementation, including the assignment of primary responsibility for implementation. The MBTA/MassDOT Team will monitor and provide quality assurance to ensure that quality programs are working at the agency itself and within the consultant and contractor organizations.

1.3 The MBTA/MassDOT policy is for projects to be planned, designed and constructed with the highest regard for quality. The Quality Assurance Plans (QAPs) submitted to the MBTA for projects completed by contractors, subcontractors, consultants and sub-consultants, shall meet the mandates outlined in the contract documents and shall be executed independent of cost and schedule project functions. The QAPs will be required to specify quality-related activities and assign responsibilities for ensuring that the activities are performed properly and achieve the stated level of quality, in accordance with FTA’s “Quality Assurance and Quality Control Guidelines, February 2002”.

1.4 Consultants and contractors are required by contract to develop and implement a QAP tailored to their scope of work. The QAPs shall provide for implementation of administrative and control measures during engineering and design, construction, testing, and start-up as appropriate. The administrative and control measures shall be prepared and implemented in such a manner as to contribute to and document the attainment of a safe, reliable, and economical transit system. QAPs from contractors, subcontractors, consultants and sub-consultants will outline specific requirements for individual activities.

The MBTA quality assurance organization, or its representative, will review and accept the quality assurance plans, quality assurance procedures, and quality control procedures of all consultants and contractors to assure the quality assurance requirements are being provided. The designated representative may not accept their own QA plans and procedures.

1.5 This PQAP will be implemented through MBTA Project Procedures that define project tasks and processes. These procedures include the MBTA Project Managers Manual, MBTA Resident Engineers manual, MBTA Field Inspectors Handbook, MBTA Quality Assurance Procedures, and MBTA lab Quality System Manual.

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

1.6 The following MBTA/MassDOT Project Management Team (PMT) members are responsible for ensuring or controlling quality on the Green Line Extension Project. The project will also include a Project Development Group (PDG), which will be organized by the PMT and will consist of technical, operations and senior management staff from the MBTA and MassDOT.

A. The MBTA General Manager guided by Administration goals and Board of Directors’ policy, directs the MBTA’s daily operations and administrative functions, and charts the Authority’s long-term strategy. The MBTA General Manager’s office establishes management policies and practices and sets standards of excellence. The Office of the MBTA General Manager assures the Authority’s accountability to the taxpayers of the Commonwealth. The MBTA General Manager directs the Authority’s support of the Commonwealth’s environmental, legislative, and economic agendas. In addition, the MBTA General Manager has the responsibility to assure the development, establishment, implementation, maintenance, and evaluation of this PQAP for the MBTA. The MBTA General Manager has delegated this responsibility to the MBTA Assistant General Manager of Design and Construction.

B. The MBTA Assistant General Manager (AGM) for Design and Construction has the ultimate responsibility for establishment and execution of the MBTA PQAP. The AGM is also responsible for coordinating and contracting design and construction activities. The AGM has the final decision on quality conflicts brought to his attention by the MBTA Deputy Director of Design and Construction, Quality Assurance.

C. The MBTA Program Manager (Director of Design and Construction – Green Line) reports to the AGM for Design and Construction and oversees all Green Line design and construction contracts and performs other administrative duties within Design and Construction. The MBTA Program Manager has the responsibility to oversee the day-to-day activities of the PM/CM Consultant or construction contractors. The MBTA Program Manager is the single point of contact for all official information on the project. The MBTA Program Manager reports to the AGM, as appropriate, and coordinates with the Project Development Group (PDG) and various MBTA departments, including but not limited to the Design Department, Development/Real Estate/Planning Department, Contract Administration, Finance Department, Vehicle Engineering, Environmental Affairs Department, Railroad/Light Rail/Bus Operations, Systemwide Accessibility Department, Safety/Security Initiatives, Transit Police Department, General Counsel, and outside or external regulatory agencies as appropriate to bring the project to completion.

D. The MBTA Deputy Director of Design and Construction, Quality Assurance reports to the AGM and has the responsibility and authority to ensure that the MBTA quality policy is implemented and maintained on projects. The Deputy Director of Design and Construction, Quality Assurance has the authority to implement quality related initiatives in all aspects of MBTA projects; to identify quality problems; to initiate, recommend or

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

provide solutions to project management, and to verify implementation of solutions. In matters related to quality on projects, the Deputy Director of Design and Construction, Quality Assurance will have complete and ready access to the PMT and the AGM.

The MBTA Deputy Director of Design and Construction, Quality Assuarance will periodically communicate with the PMCM QA Manager and resolve any outstanding project QA issues as indicated in Figure 3.

1. The MBTA Deputy Director of Design and Construction, Quality Assurance is responsible for implementation of this PQAP and ensuring that consultants and contractors submit the appropriate QAPs to the MBTA for review and approval.

2. The MBTA Deputy Director of Design and Construction, Quality Assurance conducts periodic reviews of the PQAP and quality policy to ensure that the program remains suitable and effective.

3. In cases where conflicts regarding quality cannot be resolved between the Deputy Director of Design and Construction, Quality Assurance and the MBTA Program Manager (Director of Design and Construction - Green Line), final resolution will rest with the AGM.

E. The MBTA Chief Safety Officer is responsible for administrative oversight and management of the System Safety Department and is responsible for the coordination with local, state, and federal law enforcement agencies, as well as the MBTA Police. The MBTA Chief Safety Officer ensures the MBTA complies with federal, state, and local, when applicable, laws, statutes, regulations, rules, and guidelines for safety. The MBTA Chief Safety Officer shall direct all programs involving accident and safety investigations, fire and accident prevention, hazard identification, safety audit activities, and construction and environmental safety. The MBTA Chief Safety Officer serves as the liaison with the Massachusetts Department of Public Utilities – Transportation Division and other external departments/agencies as designated by the MBTA General Manager.

F. The MassDOT Director of Strategic Planning is a senior member of the MassDOT Planning Department and identifies critical issues and strategic initiatives focusing on transit oriented development, system expansion opportunities, and infill station development. The MassDOT Director of Strategic Planning develops strategic recommendations to management and provides support to the Secretary of Transportation.

G. The MassDOT Program Manager will support the MBTA with day-to-day coordination activities of the Green Line Extension Project. The MassDOT Program Manager will act as liaison with the FTA and with the public. The MassDOT Program Manager reports to the MassDOT Director of Strategic Planning, as appropriate, and coordinates with the

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

PDG and the various MassDOT departments, including but not limited to the Planning Department, the Rail & Transit Division, Contract Administration, Highway Department, Finance Department, and General Counsel.

H. The MBTA Director of Contract Administration governs the Authority’s solicitation, award and administration of architect-engineer contracts, and coordinates the award of construction contracts.

I. The MBTA Director of Vehicle Engineering oversees the engineering for MBTA’s fleet programs including the replacement and rehabilitation of fleet vehicles and system integration.

J. The Program Management/Construction Management (PM/CM) Consultant is responsible for managing the day to day activities of the Design-Build contract (when issued). During preliminary engineering, the PM/CM Consultant is responsible for assisting the MBTA and MassDOT with the development of design documents, financial analysis, coordination with FTA and development of Design-Build contract documents. The PM/CM Consultant shall review the design concepts and assist in developing the manuals and procedures to be used in managing the Design-Build contractor such as the Project Management Plan (PMP), QAP, etc. The PM/CM Consultant shall assist in the preparation of bid documents, review bidder documents and participate in the selection of the Design-Build contractor.

1.7 The organization chart for the MBTA/MassDOT Project Management Team is provided in Figure 1 and reflects the relationship of the personnel discussed above. The organization chart for the PM/CM Consultant team is provided in Figure 2. A summary organization chart of the combined MBTA/PM/CM Team is provided on Figure 3. Additional information regarding the Green Line Extension Project organization is found in Chapter 2 of the PMP. Figure 4 depicts the precedence levels of documents that specify quality requirements or actions.

1.8 The MBTA Deputy Director of Design and Construction, Quality Assurance or his designated representative will perform scheduled QA audits of the consultants and contractors. The written audit report prepared by the audit leader will be provided to the AGM. The status of the quality program at the MBTA/MassDOT will be on the agenda at Senior management meetings.

1.9 The MBTA reserves the right for the Deputy Director of Design and Construction, Quality Assurance or his designated representative to participate in the review/disposition of consultants and contractors quality assurance documents, such as audit reports, nonconforming reports, corrective actions, etc.

1.10 The Deputy Director of Design and Construction, Quality Assurance and the PM/CM Quality Assurance Manager (as shown on Figure 3), or other consultant or contractor quality

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

assurance managers, shall have a direct line of communication to discuss quality matters and immediate and potential quality issues or concerns

1.11 The MBTA/MassDOT recognizes that the quality of the work conducted for the project has a direct effect on future revenue service, maintenance costs and operating efficiency for the entire MBTA transit system. The success of the MBTA and MassDOT is reliant upon quality, which is the measure that their existing ridership and new riders using the system will use to determine the value of the Massachusetts transit system. It therefore follows that the quality policies and procedures identified in this PQAP submitted to the MBTA/MassDOT must be faithfully implemented by every project participant.

END OF SECTION

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE MANUAL

for the Green Line Extension Project

Figure 1 MBTA/MassDOT Green Line Extension Project Organization Chart

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

Figure 2 PM/CM Organization Chart

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

Figure 3 Green Line Extension Project Organization Chart

MBTA Design Dept.

Budget Analyst Staff Assistant

PM/CM (HDR/Gilbane)

HDR/Gilbane QA Manager

Track (HDR)

Structure (HDR/SEA)

Stations (SEA)

Project Controls (Gilbane)

Director for Design & Construction (Mary Ainsley)

Director of Engineering & Design (vacant)

Deputy Director QA QC

(Jack Donovan)

AGM for Design & Construction

(Edmond Hunter, acting)

Project Manager for Design & Construction

(vacant)

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

2.0 DOCUMENTED QUALITY MANAGEMENT SYSTEM

Purpose

Section 2 of this PQAM establishes quality requirements, responsibilities and procedures for, Documented Quality System, Element 2 of the FTA’s QA/QC Guidelines.

2.1 The MBTA has established a documented quality management system for projects, documented in this PQAP. Figure 4, Quality Assurance Plan Document Precedence presents the procedural manuals that comprise the MBTA Quality Management System. Consultants and contractors, and their subcontractors and suppliers, are also required to establish documented quality management systems meeting the requirements of current FTA Quality Assurance and Quality Control Guidelines.

2.2 Written procedures and instructions will be developed for activities affecting quality including:

Design Control Document Control Purchasing Product Identification and Traceability Process Control Inspection and Testing Inspection, Measuring and Test Equipment Inspection and Testing Status Nonconformances Corrective Actions Quality Records Quality Audits Training

Procedures utilized on projects will contain a statement of the purpose and scope and will reference codes, standards, or specifications as applicable. When developing quality procedures during the course of projects, consideration will be given to identifying and acquiring any inspection equipment, skills, or special quality processes needed to ensure quality performance. Inspection and testing techniques will be kept up-to-date. Where new techniques are being used for construction or manufacturing, adequate time will be allowed to develop appropriate quality procedures for the new techniques. Procedures and instructions will contain formats for the quality records needed to ensure that the procedures and instructions are followed and documentation requirements are understood.

2.3 Project personnel conducting oversight activities, including quality audits and surveillance, and inspection activities shall be independent of those having direct responsibility for the activities being overviewed or inspected. Checking of design

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

documents shall be conducted by individuals that are qualified and experienced and are capable of conducting such design work.

END OF SECTION

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

Figure 4 Quality Assurance Plan Document Precedence

Level I Quality Commitments and Responsibilities

Level II Quality Task Implementation

Level III Quality Actions

MBTA Policies MassDOT Policy Documents

Project Quality Assurance Plan (PQA Plan)

Standard Specifications

Project Management Manual

Project Contract Specifications

Purchasing Dept. Procedures

Quality Assurance Procedures

Design/Engineering Procedures

Vehicle Procurement Procedures

Purchase Orders

Resident Engineer’s Manual

Quality Assurance Procedures

Field Inspectors Handbook

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

3.0 DESIGN CONTROL

Purpose

Section 3 of this PQAM establishes quality requirements, responsibilities and procedures for Design Control, Element 3 of the FTA Quality Control and Quality Assurance Guidelines. Additional references include Section 16 (Project Manager Responsibilities) of the MBTA Project Management Manual, and MBTA Standard Specifications on the MBTA web portal.

3.1 The MBTA provides design direction to the PM/CM Consultant. The PM/CM Consultant has been contracted by the MBTA for advanced conceptual design, preliminary engineering and the procurement of a Design/Build team. The PM/CM Consultant in conjunction with their sub-consultants will direct their day-to-day design work and will have the primary responsibility for design control during the preliminary design process. The PM/CM Consultant will establish and maintain procedures that meet the current requirements of the FTA Quality Assurance and Quality Control Guidelines for control of the preliminary design to ensure that the design criteria and other design input document requirements are met by the output documents.

The initial PM/CM Scope of Work includes advancing much of the project to a 30% design level. It also includes taking 5 bridges (Phase 1) to an advanced level of design. (The PM/CM QA/QC Plan for this phase of work is included in Appendix A.) Design verification activities will include the independent checks of design calculations, specifications, drawings, and contract documents, conducting and documenting design reviews. If appropriate, carrying out of alternative calculations, undertaking qualification tests and demonstrating or comparing the design with a similar proven design, if available, will be used to verify the design. Design reviews include reviews for constructability, operability, maintainability, and reliability.

3.2 Designs will be based upon MBTA design criteria and standards and will incorporate local jurisdiction requirements and criteria to safeguard functional operations. The MBTA will provide the PM/CM Consultant, as appropriate, with MBTA design input requirements. These requirements may be identified through regular design coordination meetings, led by the MBTA Program Manager, with MBTA departments such as Construction, Operations and Maintenance. MBTA-supplied design input documents will be reviewed by the MBTA and any ambiguities in the documents will be resolved between the MBTA and the consultant.

3.3 The MBTA will conduct reviews of all design output documents received from the PM/CM Consultant. In addition, the MBTA will approve key PM/CM Consultant personnel, including QA personnel, staff levels, qualifications of specialty design subcontractors, the consultant QAP and conduct quality audit reviews. The MBTA maintains procedures for conducting design reviews of output design documents and for other MBTA oversight activities. The review procedures will ensure that design output documents submitted by the

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PM/CM Consultant are reviewed by appropriate personnel from MBTA Design and Construction, Quality Assurance, Operations, Maintenance and other MBTA Departments, as necessary.

3.4 The project will also include a Project Development Group (PDG), which will be organized by the PMT and will consist of technical, operations and senior management staff from the MBTA and MassDOT. Technical areas of expertise for the PDG will include, but not be limited to, commuter rail, light rail, planning, systems, power, bus, highway, vehicles, legal, contracts, and administration, etc.

3.5 If the MBTA determines that a proposed design does not meet the general requirements of the design input documents, the MBTA will resolve these issues during the design review process. If there is a compelling reason to deviate from the design input documents, then the MBTA shall document any deviation. An MBTA Design Change Request will be issued for approval outlining any design deviations. The MBTA Design Change Request is contained in the MBTA Quality Assurance Manual, Section 12.1, Problem Reporting and Resolution. The MBTA Program Manager will recommend a modification to the design input documents to the Deputy Director of Design and Construction, Quality Assurance and the AGM.

3.6 Specifications and drawings will be prepared following a standard format. Specifications will identify each section and paragraph by number. Complete drawing lists will be established and the total number of drawings, the titles of the drawings, the revision status, and the dates the drawings were approved will be recorded. Changes to approved drawings and specifications will be reviewed by the same departments and organizations that reviewed the original design.

3.7 Contract specifications will require as-built drawings to be prepared at project close-out as part of the final design documentation.

3.7 A design configuration matrix shall be prepared by the designer for each construction contract indicating the revision history and latest version of each design drawing and specification issued for construction. This matrix shall list the document name, type, number, revision number, and issuance/revision date. The matrix shall also list Requests for Information (RFIs) and change orders as these may also impact the design. The configuration matrix shall be issued by the designer to the MBTA Resident Engineer on a weekly basis. The Resident Engineer shall provide the configuration matrix to the contractor at the weekly job progress meetings for the contractor’s use in the field to ensure that all work is being performed in accordance with the latest version of the design documents.

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4.0 DOCUMENT CONTROL

Purpose

Section 4 of this PQAM establishes quality requirements, responsibilities and procedures for Document Control, Element 4 of the FTA Quality Control and Quality Assurance Guidelines. Additional references include Section 12 (Records Storage) of the MBTA Project Management Manual and Section 4.1 (Filing System/Records) of the MBTA Resident Engineers Manual.

4.1 The MBTA has established procedures for control of MBTA project documents that ensure that all relevant documents are current and available to all users who require them. In addition, MBTA consultants, contractors and their subcontractors and suppliers, are required to establish and maintain procedures that describe their methods to control documents on the project.

4.2 Project document control procedures address the requirements for the review and approval of documents by authorized personnel, the distribution and storage of these documents, the elimination of obsolete documents to prevent inadvertent use, and the control of changes to the documents. Copies of documents are required to be available at the locations that need them for the effective functioning of the quality management system and obsolete documents that exist in hard copy are required to be promptly eliminated from each work location. Hard copy superseded documents retained for the record at work locations must be clearly identified as such. Unless otherwise specifically authorized by governing procedures, changes to documents are to be reviewed and approved by the same authorized personnel who reviewed and approved the originals. When the design needs to be adjusted during construction, the required documentation needs to be issued, approved and recorded. Changes to documents are required to be promptly distributed to work locations and lists of documents made available that enumerate the current revision levels of documents.

4.3 Project documents requiring control include but are not limited to:

MBTA Project Management Manual MBTA Resident Engineer’s Manual MBTA Field Inspectors Handbook MBTA Purchasing/Procurement Procedures Project Management Plan Quality Assurance Plan MBTA Quality Assurance Procedures Safety and Security Plan Real Estate Management Plan Utility Management Plan Contracts, Subcontracts, Purchase Orders, and changes

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Project Quality Plans Project Procedures (including inspection and testing procedures) Project Correspondence Project Implementation Plans, if used Project Procurement Plan, if used Design Criteria and associated standards, specifications and changes Drawings Specifications Calculations Design Change Requests Non-Conformance Reports Request for Information

4.4 Documents will be logged, indexed, and maintained in an electronic database system or file cabinets as appropriate with access restricted to authorized personnel. Documents will be protected from deterioration during storage, and fire protection will be afforded to important documents. All Green Line Extension Project electronic files shall be tracked through a formal data file system that is utilized by the Project team. Access to the project electronic files shall be password-protected. All electronic files need to be backed up regularly to an off-site facility. A design output index will be maintained that lists the latest revision of design documents (that specify quality requirements) developed for the execution of the project.

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5.0 PURCHASING

Purpose

Section 5 of this PQAM establishes quality requirements, responsibilities and procedures for Purchasing, Element 5 of the FTA Quality Control and Quality Assurance Guidelines. Additional references include Section 6 and 7 of the MBTA Project Management Manual and Section 7 of MBTA Professional Services Contracts

5.1 The majority of purchasing for projects is performed by contractors and consultants. For MBTA supplied materials and contracts, the MBTA has established procedures for the control of MBTA purchasing activities. Consultants and contractors will establish purchasing procedures to cover their activities and assure that their sub-consultants and suppliers maintain QA Plans for project activities. The MBTA performs quality audits and surveillance inspections for monitoring the performance of consultants and contractors to assure that purchasing documents are reviewed by appropriate personnel and include appropriate quality requirements. Procedures for the advertising, bidding, and awarding of construction contracts, and the selection and awarding of consultant contracts, are detailed in Section 6 (Construction Contracts) and Section 7 (Consultant Selection) of the MBTA Project Management Manual and Section 7 of MBTA Professional Services Contracts.

5.2 The Contract Administration Department performs the following activities on MBTA projects for Professional Service Contracts and Construction Contracts:

A. Selects and awards contracts for consultants to provide professional services contracts;

B. Advertises and awards construction contracts; and

C. Reviews consultant contract amendments and construction change orders.

5.3 The Materials Department performs the following activities when procurements are made by the MBTA on a project:

A. Procures materials and services for MBTA Design and Construction projects when requested;

B. Utilizes bidding methods including competitive bidding, competitive negotiations and two-phase procurement; and

C. Recommends award of materials and services contracts.

5.4 Purchasing procedures utilized by the MBTA, contractors, consultants and subcontractors will address the following requirements:

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A. Documented lists of acceptable suppliers and contractors will be established for the desired service or product, consistent with applicable procurement requirements. Selection of suppliers and contractors will be based upon their ability to meet contract requirements, including quality requirements.

B. The level of quality requirements applied to consultants, contractors, and subcontractors will be based upon the complexity and importance of the service or product being supplied. Applicable quality program requirements shall be defined in MBTA procurement and contract documents and applicable elements shall be passed down by contractors to their subcontractors and suppliers.

The Deputy Director of Design and Construction, Quality Assurance or the responsible quality assurance organization will review the quality requirements of products and services being supplied before issue to assure thee appropriate quality assurance requirements are included.

C. The contract or purchase document will clearly specify the expectations of the purchaser, including relevant standards, drawings, specifications, process requirements, inspection instructions, and approval criteria for materials, processes and product. Purchasing documents are reviewed and approved by a designated contractor or consultant authority for adequacy of specified requirements, including quality requirements, prior to release. The purchaser of services or product will ensure that the supplier fully understands the contract, agrees with the contract, and has the capacity to perform as required.

D. The contract or purchase agreement will specify the right of the MBTA, or their representative, and the purchaser to carry out reviews, examination, audit, or inspection and test of the work at the location of the work.

E. Upon receipt, material will be inspected to verify that the work or product meets requirements. Such provisions will not absolve the supplier of the responsibility to provide acceptable work or product nor will these provisions preclude subsequent rejection.

F. Where special equipment procurement is involved, the purchaser will define, as appropriate, the means and methods for handling, storage, packaging, and delivery of product. Otherwise the product will be shipped, handled and stored as recommended by the manufacturer. The purchaser will establish procedures to receive, inspect, store, and maintain equipment procured as specified. Any equipment that is damaged or is otherwise unsuited for use will be documented and reported to the supplier.

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6.0 PRODUCT IDENTIFICATION AND TRACEABILITY

Purpose

Section 6 of this PQAM establishes quality requirements, responsibilities and procedures for Product Identification and Traceability, Element 6 of the FTA Quality Control and Quality Assurance Guidelines. Additional references include Section 5 (Equipment Calibration) of the MBTA Quality System Manual.

6.1 MBTA, contractors and subcontractors and suppliers, shall address product identification and traceability requirements in their PQAPs and procedures. Traceability means that items are traceable to a particular project; specific warranty, test report, or supplier; point in time; purchase order or through production. Raw materials will be traceable back to a particular batch number, shipment number, packing slip, or invoice and will be accompanied by applicable test data sheets and material certifications, if applicable.

6.2 These PQAPs, procedures, work instructions and monitoring information will require the identification and control of items of production (batch, materials, parts, and components) to prevent the use of incorrect items and to ensure that only correct and acceptable items are used and installed.

6.3 Materials and equipment requiring traceability to their origins for purposes of laboratory analysis, etc. will be uniquely identified and tracked to assure that acceptable materials are installed in the appropriate end use. These items will be traceable to heat, lot or batch or laboratory analysis. Examples of items requiring traceability up to installation include but are not limited to:

Structural Steel Welding consumables – up to installation (Weld rod and wire, inserts, backing rings

etc.) Rebar Paint Raw materials requiring laboratory analysis

6.4 Physical identification and control will be used as required by the specifications and drawings such as bar codes, model or serial numbers, etc. Markings and other means of identification will be approved by the Authority. For items where physical identification is not stated or is impractical, physical separation, procedural control, or other appropriate means will be employed. Items that fail to possess identification, or items for which record traceability has been lost, or items that do not conform to requirements will be separated if practicable, or identified by other means, to prevent use or installation. Items will be required to be identified by how they are marked or where they are located. Store room or inventory tracking procedures will allow items to be traceable back to a particular order number, batch

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number, date received, test lot, or other pertinent source. All operating and sensitive equipment shall be properly stored and maintained prior to installation.

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7.0 PROCESS CONTROL

Purpose

Section 7 of this PQAM establishes quality requirements, responsibilities and procedures for Process Control, Element 7 of the FTA Quality Control and Quality Assurance Guidelines. Additional references include the MBTA Field Inspectors Handbook.

7.1 The MBTA will inspect and monitor all project special processes. Special processes shall:

A. Specify requirements where needed.

B. Require monitoring of important product characteristics.

C. Ensure work processes are performed in the proper sequence.

D. Evaluate processes to determine if outputs meet contract specifications.

7.2 Credentials of laboratories, technicians, and inspectors performing special process testing and inspections and job control testing shall be reviewed for compliance to applicable codes and standards and accepted by the MBTA before related work is authorized to start. All test reports will be reviewed by the MBTA Project Manager or designee.

7.3 Third party vendors acting as sub-contractors or suppliers will maintain both test reports and company certifications, and make available for review by the MBTA.

7.4 Test reports prepared by third party consultants for acceptance do not absolve the general contractor for responsibility in providing acceptable construction materials.

7.5 If new process control procedures are required the related work shall not be authorized to start until the applicable procedures are developed and accepted by the MBTA.

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8.0 INSPECTION AND TESTING

Purpose

Section 8 of this PQAM establishes quality requirements, responsibilities and procedures for Inspection and Testing, Element 8 of the FTA Quality Control and Quality Assurance Guidelines. Additional references include the MBTA Field Inspectors Handbook, which provides inspection procedures/checklists for each type of work broken down by specification division to be used by the MBTA field inspectors.

8.1 The MBTA requires contractors and subcontractors, who purchase equipment, perform manufacturing and/or construction, perform installation of equipment, and/or perform testing to develop quality plans and inspection and test procedures. Contract documents will identify mandatory inspections and tests. The project documents will identify “hold” and “notification” points to contractors, subcontractors and suppliers. Inspections and tests will be performed by qualified individuals and the results reported and documented.

8.2 Personnel performing inspections and tests on the project shall be independent of those having direct responsibility for the construction or installation of the items being inspected or tested. Contractors are not relieved of responsibility based on inspections and tests conducted by the MBTA or MBTA-delegated organizations.

8.3 Test laboratories that are utilized on projects to conduct testing such as soil testing, aggregate testing, concrete testing, welding inspection and testing, nondestructive examinations, and calibration of measuring and test equipment and any special requirements by the MBTA will be qualified to perform the activity in accordance with the governing codes and standards and jurisdictions.

8.4 Quality plans and related inspection and test procedures will address requirements for in-process and final inspection during production, installation and testing activities. The preliminary engineering phase will identify items or work affecting safety, system reliability, service life, and long lead times needed for final design and construction phases.

A. Procedures will address requirements for the conduct of in-process inspection and tests to verify conformance of items or work activities to specified requirements. Both inspection and process monitoring methods will be performed, as necessary, to ensure that the specified requirements for control of work processes and the quality of the item are achieved throughout the duration of the work.

B. Quality plans and procedures will address requirements for the final inspection and test to ensure that all specified inspections and tests have been satisfactorily completed and documented.

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8.5 Quality plans and procedures will address requirements for documentation of inspections and tests with records that show clearly whether the product has passed or failed the inspections or tests in accordance with defined acceptance criteria. Where the product fails to pass inspections or tests, nonconformance control procedures, as addressed in Section 11.0 of this QAP, shall apply.

8.6 Quality plans or inspection and test procedures will make provisions for the MBTA to identify important inspection and test activities that they or their representative may observe. The MBTA or their representative will classify each inspection or test activity identified for possible observation as either a hold point or a notification point. Notification of these activities will be made to the MBTA or their representative in advance of the activity in an agreed upon time frame. Inspection and test activities identified as hold points shall not be conducted until the MBTA or their representative is present unless the MBTA or their representative has formally waived the hold point in writing. Assignment of hold points will consider, as appropriate:

Items or work affecting quality Items that affect system reliability Items affecting service life Long lead items or custom manufactured items High visibility items Items that affect ADA compliance

Inspection and test activities identified as notification points may be performed as scheduled, with or without the presence of the MBTA or their representative, provided that notification has been made in the agreed upon time frame.

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9.0 INSPECTION, MEASURING, AND TEST EQUIPMENT

Purpose

Section 9 of this PQAM establishes quality requirements, responsibilities and procedures for Inspection, Measuring and Test Equipment, Element 9 of the FTA Quality Control and Quality Assurance Guidelines. Additional references include Section 6 (Sampling and Testing) of the MBTA Quality Management System.

9.1 The MBTA, and its contractors and their suppliers and subcontractors, who use inspection, measuring, and test equipment to carry out inspection and testing on projects, will establish procedures that ensure that this equipment is identified, controlled, calibrated, and maintained in order to demonstrate the conformance of work to specified requirements. Procedures will meet the requirements of ISO 10112. Compliance with Section 6 (Sampling and Testing) of Part II of the standard MBTA Quality System Manual, will be required when statistical tracking is required.

9.2 Inspection, measuring, and test equipment control procedures will address the following requirements:

A. Inspection, measuring, and test equipment that is selected for use must be capable of the necessary accuracy and precision.

B. Inspection, measuring, and test equipment whose use can affect product quality shall be identified. This equipment will be calibrated at prescribed intervals or prior to use, against equipment having a valid relationship to national standards. If no national standards exist, the basis of calibration shall be documented. Procedures or instructions for performing the calibrations will be established and used and records of calibration results maintained.

C. Inspection, measuring, and test equipment will be identified with a suitable indicator or approved identification record to show the calibration status.

D. Inspection, measuring, and test equipment will be properly maintained to ensure its fitness for use. Suitable environmental conditions shall be maintained when the equipment is in use. Calibration equipment found to be out of calibration shall be tagged and taken out of service and a review completed of previous calibration records for the piece of equipment. The results of the calibration test shall be documented on a Non-Conformance Report.

E. Where test software or test hardware is used for inspection, this software or hardware will be checked to prove it is capable of verifying the acceptability of a product prior to its use and shall be periodically rechecked at proscribed intervals.

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9.3 Inspection, measuring, and test equipment control procedures are in the latest version of the MBTA Lab “Quality System Manual”.

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10.0 INSPECTION AND TEST STATUS

Purpose

Section 10 of this PQAM establishes quality requirements, responsibilities and procedures for Inspection and Test Status, Element 10 of the FTA Quality Control and Quality Assurance Guidelines. Additional references include Resident Engineer Procedure No. REP 4.2 of the MBTA Resident Engineers Manual.

10.1 Consultants will establish processes and procedures to assure design documents are reviewed at appropriate intervals and that their status is maintained throughout the development process.

10.2 Prior to production and/or installation, MBTA contractors, subcontractors and their suppliers will establish processes and procedures that identify the inspection and test status of work during production and installation.

10.3 Test and inspection status will be identified by means of markings, stamps, tags, labels, routing cards, inspection records, test software, physical location, or other suitable means. Status indicators will indicate the conformance or nonconformance with regard to the inspections and tests performed.

10.4 Construction progress and status is documented in Contractor Inspection Reports, MBTA Inspection Reports and Inspector Diaries and in the Resident Engineers Diary. Additionally, status is verified during the monthly cost estimate processing system.

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11.0 NONCONFORMANCES

Purpose

Section 11 of this PQAM establishes quality requirements, responsibilities and procedures for Nonconformances, Element 11 of the FTA Quality Control and Quality Assurance Guidelines. Additional references include Section 12.1 (Problem Identification and Resolution) of the MBTA Quality Assurance Manual.

11.1 MBTA contractors and their suppliers and subcontractors, who purchase equipment, perform manufacturing and/or construction, perform installation of equipment, and/or perform testing will develop and submit procedures for the control of nonconforming work. These procedures will be written to ensure that nonconforming work is not inadvertently used or installed.

Quality Assurance Procedure No. QAP-12.1, Problem Identification and Resolution, establishes the methods to be used by the MBTA Resident Engineer to document and process requests for information from the Designer, design changes, and nonconformances. This procedure includes forms and instructions for resolution reports, requests for information (RFI), and RFI and resolution report logs.

The following nonconformance-related definitions apply to the project:

Nonconformance – A discrepancy in characteristic, documentation, or procedure that affects form, fit or function and renders the quality of an item unacceptable or indeterminate in regard to meeting all relevant project requirements. Examples of nonconformances include physical defects; test failures; incorrect or inadequate documentation; or deviation from prescribed processing, inspection, or test procedures.

Accept-as-is – A disposition of a nonconforming item when it can be established that the item is satisfactory for its intended use. The Authority will establish a format for accepting compensation for “Accept-as-is” dispositioned work.

Rework – A disposition of a nonconforming condition that indicates that the deficiency can be brought into conformance with the original requirements through re-machining, reassembly, reprocessing, reinstallation, or completion of the required operations.

Repair – A disposition of a nonconforming condition that indicates that an item can be made acceptable for its intended use, even though it is not restored to a condition that meets all specification requirements.

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Reject – A disposition of a nonconforming condition that indicates that the item cannot be reworked or repaired to meet specification requirements.

11.2 Project nonconformance procedures will address the following requirements:

A. Nonconforming work will be identified, documented, and evaluated to determine appropriate disposition. Nonconforming items will be clearly identified as nonconforming and where practicable, segregated to prevent inadvertent installation. The organization performing activities affected by the nonconforming work will be notified.

B. The responsibility for review and disposition of nonconforming work is contained in the MBTA QA Procedures. Nonconformances will be dispositioned as accept-as-is, rework, repair or reject. Dispositions will be documented. All dispositions will be reviewed and approved by the responsible design organization.

C. Reworked or repaired work will be reinspected in accordance with established procedures.

D. The project group responsible for maintaining the status of nonconformances will be identified.

11.3 All nonconformances will be approved by the MBTA when resolved. Non-conformances will be documented on MBTA standard non-conformance forms.

11.4 The status of nonconformances will be maintained by the MBTA. A monthly status report of all project non-conformances will be issued at least monthly.

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12.0 CORRECTIVE ACTION

Purpose

Section 12 of this PQAM establishes quality requirements, responsibilities and procedures for Corrective Action, Element 12 of the FTA Quality Control and Quality Assurance Guidelines. Additional references include Quality Assurance Procedure No. 13.1 (Corrective Action) of the MBTA Quality Assurance Manual.

12.1 The MBTA has established project procedures for identifying, documenting, correcting, and preventing recurrence of conditions adverse to quality. MBTA Quality Assurance will log and file Corrective Actions. In addition, MBTA contractors and their subcontractors and suppliers, are required to establish corrective action procedures.

MBTA Quality Assurance Procedure No. QAP-13.1, Corrective Action, establishes the methods, requirements, and actions required to identify conditions adverse to quality, determine their cause, and provide effective corrective and preventative action. This procedure includes a corrective action log form.

12.2 Project corrective action procedures will be established for:

A. Investigating the cause of nonconforming product(s) and taking the corrective actions needed to prevent recurrence;

B. Analyzing processes to detect and eliminate potential causes of nonconforming product(s) or conditions adverse to quality;

C. Initiating preventive actions to deal with problems to a level corresponding to the risks encountered;

D. Ensuring that corrective actions are taken and that they are effective; and

D. Implementing and recording changes in procedures resulting from corrective action.

12.3 Revised procedures prompted by corrective actions will be approved by the appropriate MBTA personnel.

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13.0 QUALITY RECORDS

Purpose

Section 13 of this PQAM establishes quality requirements, responsibilities and procedures for Quality Records, Element 13 of the FTA Quality Control and Quality Assurance Guidelines. Additional references include Secton 12 (Records Storage) of the MBTA Project Management Manual and Quality Assurance Procedure No. 14.1 (Quality Records) of the MBTA Quality Assurance Manual.

13.1 The MBTA has established procedures for the accumulation and storage of project-related quality records. In addition, MBTA contractors and their subcontractors and suppliers, will establish and maintain procedures for accumulation, turnover and storage of quality records. Quality Assurance Procedure No. QAP-14.1 (Quality Records) of the MBTA Quality Assurance Manual and Section 12 (Records Storage) of the MBTA Project Management Manual establish the requirements for the retention and storage of quality records.

13.2 Project quality plans and procedures related to quality records identify which records will be kept, the responsibility for production and collection, and responsibility for indexing, filing, storage, maintenance, and disposition of quality records. Quality records will be maintained to show achievement of quality objectives and appropriate functioning of the quality management system. Each organization generating quality records will prepare a quality records list that identifies every type of document generated as a result of implementing the quality program. Types of quality records include but are not limited to: Design reviews Drawings and specifications Calculations Design changes Procurement documents Procedures and instructions Quality Plans Calibration records Audit and Surveillance Reports Corrective actions Test data Geotechnical Reports Survey Reports Inspection Reports (including Nonconformance Reports).

13.3 Quality records shall be complete, legible, specify the work involved, and be kept in an environment to minimize deterioration and damage. Quality records shall be identified by title and contract number. Records will be protected from fire condensation, extreme

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

temperature variations, rodents and pests. Access to quality records will be controlled to prevent alteration, damage, or loss. Where specified by contract, quality records should be made available to the purchaser or purchaser's representative.

13.4 Quality records shall be maintained until the completion of projects, in accordance with MBTA records retention policies. MBTA project quality records are maintained by the responsible groups until the project is completed.

END OF SECTION

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

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14.0 QUALITY AUDITS

Purpose

Section 14 of this PQAM establishes quality requirements, responsibilities and procedures for Quality Audits, Element 14 of the FTA Quality Control and Quality Assurance Guidelines. Additional references include Quality Assurance Procedure No. 15.1 (Audits) of the MBTA Quality Assurance Manual.

14.1 To ensure that each project’s quality system are functioning as intended, the MBTA has established procedures for the conduct of internal and external quality audits of consultant’s QA/QC program and D/B contractor QA/QC program. In addition, contractors, subcontractors, suppliers and consultants will establish procedures that address their audit process. MBTA Quality Assurance Procedure No. QAP-15.1, Audits, describes the methods for performing MBTA quality assurance audits and establishes auditor qualification requirements. This procedure includes forms for audit schedules, plans, checklists, and observation. MBTA QA Audits will cover the full scope of the project.

14.2 Project procedures for quality audits shall address the following requirements:

A. Audit schedules will be issued and periodically updated. Audit frequency will depend upon the status and importance of the activity being audited. For internal audits, each element of the applicable quality program shall be audited at least annually and the results of previous audits, quality control inspections and other quality indicators shall be evaluated as part of the audit.

B. Lead auditors and auditors will be qualified based on education, experience or training and their qualifications will be documented. The qualification requirements for auditors will be defined. Audits shall be carried out by personnel independent of those having direct responsibility for the activity being audited.

C. Audit checklists will be provided to audited organizations in advance of each audit. Audits will be conducted using checklists prepared in advance of the conduct of the audit and approved by the Deputy Director of Design and Construction, Quality Assurance.

D. The results of audits shall be presented to the management of the audited organization by the audit team at the conclusion of the audit. This presentation will be followed by the timely issuance of a written audit report by the audit team leader. The audit report will be issued to the management of the audited organization and the AGM with copies to management of other affected organizations as appropriate.

E. The management of the audited organization will correct any deficiencies identified by the audit in a timely manner. The organization that conducted the audit will track

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

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audit deficiencies, report on their status, and perform corrective action audits as necessary.

F. The MBTA will also complete Quality Assurance Surveillances between Quality Assurance Audits. The surveillances shall include a partial check on consultants, contractors and sub-contractors,

14.3 Audit reports are provided to the Deputy Director of Design and Construction, Quality Assurance who will check on the status of audit deficiencies on a monthly basis. Copies of audit reports are provided to the AGM for Design and Construction, the Director of Design and Construction, the MBTA Program Manager (Director of Design and Construction – Green Line), and the Deputy Director of Design and Construction, Quality Assurance, as appropriate.

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Massachusetts Bay Transportation Authority PROJECT QUALITY ASSURANCE PLAN

for the Green Line Extension Project

15.0 TRAINING Purpose

Section 15 of this PQAM establishes quality requirements, responsibilities and procedures for Training, Element 15 of the FTA Quality Control and Quality Assurance Guidelines. Additional references include Quality Assurance Procedure No. 16.1 (Training and Certification of Inspectors) of the MBTA Quality Assurance Manual.

15.1 MBTA personnel assigned to projects are trained and qualified in accordance with the requirements of this PQAP and project procedures. A training matrix will be developed for each organization to help determine which personnel require training in which procedure(s). Training procedures will be established to ensure personnel performing activities affecting quality are qualified on the basis of appropriate education, experience and/or training. MBTA Quality Assurance Procedure No. QAP 16.1 (Training and Certification of Inspectors) establishes the training and certification requirements for MBTA field inspectors.

15.2 The AGM assures that all MBTA personnel that are assigned responsibilities on projects are qualified based upon education, skills, abilities, experience, and/or training.

15.3 Records are maintained of employee qualifications and training. It is the responsibility of each MBTA Manager to assess the training needs for their direct reports. A training plan will be developed as necessary that will ensure that the direct report is properly trained to perform all work assigned to them. The training plan must identify appropriate training needs to fill gaps in the direct report’s qualifications and abilities and the resources required to meet the training needs.

15.4 The MBTA Program Manager shall identify the key project-related documents, including this PQAP, the Project Management Plan, MBTA procedures, etc., that his or her personnel must be familiar with or understand, and document these requirements on training matrices. Training on these documents may be by reading assignment or classroom instruction. All such training will be documented.

15.5 The MBTA Program Manager is responsible to ensure that key non-project MBTA staff assigned project responsibilities are adequately trained in project requirements as necessary.

15.6 The MBTA Program Manager shall maintain a training matrix summarizing training courses attended by project personnel.

15.7 Project personnel will be provided training on the GLX quality assurance procedures applicable to the services the individual will provide. In addition to the quality training, the design engineering department will provide training to internal design on design control procedures.

END OF SECTION

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