Quality Assurance/Control Procedures

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1 2015 Prgrammatic Categrical Exclusin {PCE} Agreement Oregn Department f Transprtatin Federal Highway Administratin, Oregn Divisin Quality Assurance/Cntrl Prcedures Intrductin The Prgrammatic Agreement Between The Federal Highway Administratin, Oregn Divisin And The Oregn Department Of Transprtatin Regarding Apprval Of Actins Classified As Categrical Exclusins Fr Federal-Aid Highway Prjects {2015), discussed herein as the Prgrammatic CE (r PCE) Agreement, states that the Oregn Department f Transprtatin (ODOT) agrees t develp, carry ut, and reprt n regular quality cntrl and quality assurance (QA/QC) activities t ensure that PCE apprvals are made in accrdance with applicable law, regulatin, guidance and the PCE Agreement. This dcument utlines thse prcedures. QA/QC prcedures will be applied t all ODOT PCE dcumentatin whether prduced by cnsultants, lcal public agencies, r by ODOT staff. ODOT acts n behalff the Federal Highway Administratin, Oregn Divisin (FHWA) t apprve all PCE dcuments fr prjects using Federal-aid Highway Prgram funds, including thse prjects spnsred by lcal public agencies. Quality Management Quality Assurance (QA) and Quality Cntrl (QC) measures fr the PCE Agreement are the standards and prcedures that ODOT and FHWA implement t ensure statewide decisin-making relating t the PCE Agreement is cnsistent. QA and QC measures can be accmplished cnsecutively r simultaneusly and taken tgether represent quality management f the PCE Agreement and assciated prcesses. The verall gal f quality management is t be able t measure and mnitr use f thse standards and prcedures and prvide crrectins as necessary. Quality Assurance Quality Assurance is the prcess ODOT uses t ensure PCE decisins made by Regin and Ge Envirnmental Sectin (GES) NEPA staff and managers wh prepare and apprve PCE and supprting dcuments are cnsistent with the 2015 PCE Agreement. In general, the gal f quality assurance is preventin. Quality assurance measures fr PCE prcesses prmte cnsistency f PCE prcesses and dcumentatin in cmpliance with the PCE Agreement, the PCE Guidance, and the PCE QA/QC Prcedures in rder t assure accuracy and cnsistency, and prevent redundancies and gaps relating t PCE infrmatin gathering and dcumentatin. Quality assurance measures include: Page 1

2 Keeping the PCE Agreement Guidance and QA/QC Prcedures up-t-date and readily accessible. Ensuring ODOT frms r templates that are created and/r revised fr use in preparing PCE and supprting dcuments are reviewed and apprved by FHWA, and are up-t-date. Prviding prgram-level prcess review findings and recmmendatins t PCE preparers and apprvers. Ensuring findings frm prgram-level prcess reviews are incrprated int statewide ODOT trainings, Regin Envirnmental Crdinatr (REC)/Envirnmental Prject Manager (EPM) meeting discussins, PCE Guidance, QA/QC Prcedures, r ther prcesses as apprpriate. Ensuring prfessinal qualificatin requirements, per the PCE Agreement (Sectin IV.A.8-9), are achieved and maintained by all staff and managers wh prepare and apprve PCE and supprting dcuments. Ensuring cnsistent PCE prject recrd-keeping. Quality Cntrl Quality Cntrl is the prcess ODOT uses t prepare and apprve cmplete and accurate PCE and supprting dcuments. In general, the gal f quality cntrl is detectin. Quality cntrl measures fr PCE prcesses identify incnsistencies, inaccuracies, redundancies, and gaps in PCE and supprting dcument preparatin prcesses. Quality cntrl measures include: Ensuring PCE Apprval Dcuments receive a peer review. Ensuring envirnmental manager review/signature (signifying apprval) are n PCE and supprting dcuments. Ensuring prject recrds are kept cnsistent with PCE filing prtcls including but nt limited t: file naming cnventins, strage lcatins, dcuments t be retained, and file retentin timeframes. Ensuring the implementatin f crrective actins, as apprpriate, frm PCE quality assurance review findings and recmmendatins t remedy prcess and dcumentatin incnsistencies, inaccuracies, redundancies, and gaps. PCE Prject Recrd Retentin All PCE Prject Recrds retained in Regins, and PCE dcumentatin retained in GES, will be readily available fr review, and be made available t FHWA upn request. Prject recrds must be retained fr 13 years fllwing prject cnstructin cmpletin (date final cnstructin vucher is apprved by FHWA). ODOT Regins The prject recrd fr each PCE will be retained by Regins and will include the fllwing at a minimum: Checklists, frms, maps, and ther dcuments (including and ther crrespndence) and exhibits that summarize the cnsideratin f prject impacts, unusual circumstances, and decisin-making; Page 2

3 GES A summary f public invlvement in cmpliance with the requirements f FHWA-apprved public invlvement plicy; Stakehlder cmmunicatins, crrespndence, cnsultatin, r public meeting dcumentatin that supprts prject and envirnmental decisins; and Re-evaluatin dcumentatin, when prduced. Regins will prvide the fllwing final PCE dcumentatin t GES: Final PCE Determinatin Frms. Final PCE Apprval Dcuments, and all required attachments. Prfessinal Qualificatin Requirements ODOT will ensure that nly qualified persns prepare and apprve PCE and supprting dcuments. As per the PCE Agreement (Sectin IV.8.A-C), each PCE dcument preparer and/r apprver must: Be knwledgeable with and fllw the apprpriate subsectins 23 CFR 771 thrugh 774, and FHWA and ODOT prcedures fr envirnmental analysis and NEPA cmpliance; Have cmpleted, at a minimum, Intrductin t NEPA and Transprtatin Decisin-making webbased curse FHWA-NHl (r ther NHl-NEPA training); and Have adequate experience addressing NEPA cmpliance fr transprtatin prjects r until such time have their wrk reviewed by staff having the necessary experience. GES will ensure all PCE preparers and apprvers have cmpleted, at a minimum, the web-based FHWA NHl NEPA curse. All ODOT staff and manager qualificatins, including dated certificates, will be n file in GES fr FHWA review upn request. GES will alert NEPA staff abut relevant training pprtunities, and will prvide relevant training t keep NEPA staff and managers current in FHWA PCE wrk. GES will submit the fllwing infrmatin t FHWA as part f annual reprting, per the PCE Agreement: Date individual cmpleted curse FHWA-NHl (and/r ther NHl-NEPA curse(s)); and Brief statement f the individual's experience. Rles and Respnsibilities The fllwing table lists the primary rles and respnsibilities f the ODOT and FHWA persnnel invlved in the preparatin and apprval f PCE and supprting dcuments develped fr FHWA Federal-Aid Highway Prgram prjects in Oregn. Fllwing this table, prcedures fr fulfilling these rles and respnsibilities are described in mre detail. Page3

4 QA/QC Rle Regin Envirnmental Crdinatr (REC) r Envirnmental Prject Manager (EPM) QA/QC Respnsibility Prepare and prvide peer review f PCE frms and dcuments. Maintain apprpriate level f versight and crdinatin with technical specialists fr preparatin f all applicable PCE supprting dcumentatin. Ensure the fllwing dcuments are accurate and cmplete prir t submitting t envirnmental manager fr review and apprval: PCE dcuments PCE Determinatin Frm PCE Apprval Dcument Part 3 Attachment Dcument Vicinity Map with area f ptential impact (API) identified Supprting envirnmental dcuments-esa, Sectin 106, Tribal Crdinatin Summary, Sectin 4{f), etc. Public invlvement summary, including EJ engagement Envirnmental cmmitments Re-evaluatin f PCE determinatin, as applicable Enter prject infrmatin int the applicable Regin PCE prject tracking spreadsheets fr quarterly reprting purpses. Regin Envirnmental Manager (r qualified designee) Review PCE determinatins, PCE Apprvals and re-evaluatins made by the REC r EPM, and all applicable supprting dcumentatin; prvide recmmended changes t REC/EPM. Ensure PCE dcuments are cmplete, accurate, and have received a peer review and the apprpriate level f technical specialist review. Respnsible t prvide GES with infrmatin fr quarterly and annual PCE reprts that utlines any incnsistencies r perfrmance gaps that have been nticed ver the apprpriate quarterly r annual reprting perids. Review and apprve PCE dcumentatin. Supprt Regin staff t achieve prfessinal qualificatin requirements by prviding training pprtunities and by encuraging staff t be an active participant during REC/EPM meetings. Review and apprve PCE Quarterly Reprts within timeframes f PCE agreement. Page 4

5 QA/QC Rle Ge-Envirnmental Sectin (GES), NEPA Prgram staff QA/QC Respnsibility Cnduct quarterly prgram-level prcess reviews, in crdinatin with Regins and FHWA, fr the fllwing: Apprpriateness f PCE determinatin Apprpriate applicatin f 23 CFR Cmpleteness f prject recrd Accuracy f infrmatin dcumented in bth PCE and supprting dcuments Apprpriateness f peer review and apprval signatries fr PCE Apprval Dcuments as per the PCE QA/QC Dcument Cmpleteness and Accuracy Guidance (t be develped by GES n r befre January 4, 2016) Apprpriateness f the ptential need fr re-evaluatins Prvide findings f prcess reviews t Regins and GES, and fllw-up with any needed crrective actins r adjustments including, but nt limited t: Training Mentring Guidance Plicy Crdinate with Regins t prepare and prvide timely submittal f quarterly and annual reprts t FHWA, including summary f quality cntrl and assurance findings, crrective actin recmmendatins prvided t Regins and GES staff and managers, and implementatin prgress f any crrective actins and/r prgram adjustments. Act as liaisn between Regins and FHWA fr answering questins, prviding training/mentring/assistance, etc. This des nt eliminate the pprtunity fr Regins t cntact FHWA directly. Prvide timely respnses t PCE questins frm Regin, in crdinatin with FHWA. Assist and prvide training t RECs and EPMs as needed, and cmmunicate any updates t the PCE prgram t RECs and EPMs, their managers, and ther Regin and/r GES staff as utlined in the PCE Cmmunicatins Plan. Assure GES and Regin staff and management remain qualified as per the PCE Agreement. Page 5

6 QA/QC Rle QA/QC Respnsibility FHWA Timely review f and respnse t ODOT quarterly and annual reprting. As available, participate with ODOT in prcess reviews f PCE and supprting dcument prir t quarterly and annual reprting. Prvide timely respnses t PCE questins frm Regin, in crdinatin with GES. Perfrm n-ging mnitring f ODOT's PCE prgram. Cllabrate and cperate with ODOT GES and Regins t reslve any issues, slve prblems, and prvide assistance. PCE and Supprting Dcumentatin Preparatin and Apprval Quality Cntrl Prcedures Fllwing are quality cntrl prcedures fr each PCE dcument. PCE and Supprting Dcuments PCE dcument preparers and apprvers must have the minimum training, knwledge, and experience (i.e., prfessinal qualificatin requirements) as per the PCE Agreement {IV.A.8-9). PCE and supprting envirnmental dcuments include: PCE Determinatin Frm PCE Apprval Dcument Prspectus Part 3 Vicinity map with area f ptential impact (API) utlined Supprting envirnmental dcuments as utlined in the PCE Apprval Dcument PCE Determinatin Frm Preparatin The REC r EPM is respnsible fr cmpleting the ODOT PCE Determinatin Frm. This can generally be dne shrtly after prject kickff. PCE Supprting Dcument Preparatin The apprpriate PCE supprting envirnmental dcument preparer shuld meet the minimum prfessinal qualificatin requirements as is apprpriate fr their particular discipline. Typically the Regin r GES Bilgists, Archaelgists, Histrians, and ther envirnmental specialists as applicable will prepare and/r versee the preparatin f mst ODOT envirnmental cmpliance dcuments, used t infrm and/r supprt PCE determinatins. The REC r EPM will ensure the required PCE supprting dcuments are attached t the PCE Apprval Dcument as per the PCE Guidance. Page 6

7 PCE Apprval Dcumentatin Fr PCE dcuments, the REC r EPM is respnsible fr cmpleting the ODOT Prject Prspectus Part 3 (a required dcument attachment t the PCE Apprval Dcument) as part f the prject scping phase. Once the PCE Determinatin Frm and Part 3 have been cmpleted, the REC r EPM will then prepare the PCE Apprval Dcument. The PCE Apprval Dcument will be peer reviewed by a reviewer utside f the Regin per the PCE QA/QC Cmpleteness and Accuracy Guidance, which will be develped by GES by January 4, 2016 r sner, t help guide the peer review prcess fr cnsistency and prmte exchange f best practices. The REC r EPM will submit the fllwing t the Regin r GES Envirnmental Unit Manager, r his/her qualified designee, fr apprval f the PCE dcuments: PCE Determinatin Frm PCE Apprval Frm Prspectus Part 3 All required PCE supprting dcumentatin PCE Apprval Dcument Cmpleteness and Accuracy Guidance PCE Apprval Dcuments will be peer reviewed by a reviewer utside f the Regin t assure they are cmplete, accurate, use the mst up-t-date FHWA apprved frmats and ODOT/FHWA guidance, and refer t the mst current and relevant regulatins. The REC r EPM will refer t the PCE QA/QC Dcument Cmpleteness and Accuracy Guidance (t be develped by GES n r befre January 4, 2016). PCE and Supprting Dcument Filing Varius methds are currently in use fr submitting PCE and supprting dcuments t GES electrnic file flders. In additin, ODOT is currently refining electrnic filing prtcls n a department-wide basis. New electrnic filing prcedures fr PCE and supprting dcuments will be cmpleted and implemented n r prir t December 15, Maintaining Technical Cmpetency GES will maintain files dcumenting that Regin and GES staff and managers wh prepare and/r sign fr apprval f any PCE r supprting dcument meet prfessinal qualificatin requirements (i.e., knwledge, educatin, and training), as per the PCE Agreement. These files will be updated at least annually, and any time there is a change in persnnel, especially new hires wh will prepare and/r sign fr apprval any PCE r supprting dcument. GES is respnsible t ensure that Regin and GES staff and managers maintain the required prfessinal qualificatin requirements, as per the PCE Agreement, and will wrk w ith any new staff and their managers t help them becme qualified. GES will wrk with FHWA t prvide t raining, as needed and/r as recmmended thrugh prgram-level prcess reviews and ther PCE prcess mnitring results, t help ensure Regin and/r GES staff and managers maintain their cre cmpetencies as per the PCE Agreement. Page 7

8 PCE Cmmunicatin Plan GES will develp a PCE Cmmunicatins Plan that utlines prtcls fr when and hw PCE prcess infrmatin is disseminated t and thrughut GES, Regins, and FHWA. PCE prcess infrmatin might include, but is nt limited t, the fllwing: Prcess r dcumentatin updates, including changes t frms, guidance, and ther related dcuments r prcedures; Rutine PCE prcess updates at REC and EPM meetings; Meeting annuncements; Filing and ther PCE prcess administrative guidance and/r updates; and Training pprtunities. The PCE Cmmunicatin Plan will be cmpleted and incrprated herein n r prir t February 15, The PCE Agreement will be a regular agenda tpic that is discussed during REC/EPM meetings. Discussins may include the fllwing tpics: Prcess r dcumentatin; Prject recrd and filing; Opprtunities fr imprvement; Ptential training r assistance needs; and Best practices, efficiencies and redundancies. PCE Prcess Mnitring and Prcess Reviews As per the PCE Agreement (Sectin C.), mnitring by FHWA will include cnsideratin f the technical cmpetency and rganizatinal capacity f ODOT, as well as ODOT's perfrmance f its PCE prcessing functins. Perfrmance cnsideratins include, withut limitatin, the quality and cnsistency f ODOT's PCE apprvals, prject envirnmental dcumentatin, CE submissins t FHWA fr apprval, adequacy and capability f ODOT staff and cnsultants, and the effectiveness, quality and cnsistency f ODOT's administratin f its internal PCE apprvals. FHWA will cnduct ne r mre prgram reviews as part f its versight activities, during the term f the PCE Agreement. GES will prepare and implement a crrective actin plan t address any findings r bservatins identified in FHWA prgram reviews. GES will draft the crrective actin plan within 45 calendar days f FHWA finalizing its review. The results f that review and crrective actins taken by ODOT will be cnsidered at the time the PCE Agreement is cnsidered fr renewal. GES NEPA Prgram staff and managers will cllabrate with Regin and FHWA staff t perfrm quarterly prgram-level prcess reviews f PCE prject recrd files pri.r t each quarterly reprt preparatin. Findings frm all PCE reviews may dictate the need fr further reviews. Michelle Eraut, Prgram Develpment Team Leader Federal Highway Administratin {)~.t.1 /<J!S- Date Page 8

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