Module 17 Quality Management, Technical Review and Model Certification

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Module 17 Quality Management, Technical
Review and Model Certification
Civil Works Orientation Course - FY 11
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Objectives

• This module will discuss
• District Quality Control (DQC)
• Agency Technical Review (ATR)
• Independent External Peer Review (IEPR)
• Roles of Technical Centers
• of Expertise
• Model Approval/Certification

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Why The Corps Does Review

• An extra set of eyes is good.
• To ensure consistent application of policy,
  guidance, design criteria, etc across the nation.
• USACE Goal is to always provide the most
  scientifically sound, sustainable water resource
  solutions for the U.S.
• There are numerous statutory and Administration
  requirements for various reviews.

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Examples of Statutory and Administration
Requirements

• Section 2034 of PL 110-114 WRDA 2007
• Section 2035 of PL 110-114 WRDA 2007
• Section 515 of PL 106-554 Information Quality
  Act
• Final Information Quality Bulletin for Peer
  Review AKA the OMB Peer Review
  Bulletin
• EC 1165-2-209 Life-cycle review strategy for
  Civil Works Projects

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Section 2034 WRDA 2007 (Public Law 110-114)

• IN GENERAL- Project studies shall be subject to
  a peer review by an independent panel of experts
  and subject to mandatory and exclusions.
• The first time Congress established by law the
  requirement of the Corps to have decision
  documents reviewed by independent external
  experts.

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Exclusions

• Chief may exclude
• No EIS and
• not controversial
• negligible adverse impacts on scarce or unique
  cultural, historic, or tribal resources
• no substantial adverse impacts on fish wildlife
  and their habitat prior to mitigation and
• before mitigation, only negligible adverse impact
  on a species listed as endangered or threatened
• only rehabilitation/replacement of existing
  hydropower turbines, lock structures, or flood
  control gates within the same footprint and for
  the same purpose as an existing water resources
  project
• is for an activity for which there is ample
  experience within the Corps of Engineers and
  industry to treat the activity as being routine
  and
• has minimal life safety risk or
• does not include an environmental impact
  statement and is a project study pursued under CAP

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Legislative History from Conference Report

• Section 2034 permits the Chief of Engineers to
  exclude a very limited number of project studies
  from independent peer review. The managers expect
  that project studies that could be excluded from
  independent peer review are so limited in scope
  or impact that they would not significantly
  benefit from an independent peer review.

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Section 2035 WRDA 2007

• The Chief of Engineers shall ensure that the
  design and construction activities for hurricane
  and storm damage reduction and flood damage
  reduction projects are reviewed by independent
  experts under this section if the Chief of
  Engineers determines that a review by independent
  experts is necessary to assure public health,
  safety, and welfare.
• (b) Factors- In determining whether a review of
  design and construction of a project is necessary
  under this section, the Chief of Engineers shall
  consider whether--
• (1) the failure of the project would pose a
  significant threat to human life
• (2) the project involves the use of innovative
  materials or techniques
• (3) the project design lacks redundancy or
• (4) the project has a unique construction
  sequencing or a reduced or overlapping design
  construction schedule.

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• Treasury and General Government Appropriations
  Act for Fiscal Year 2001
• (Public Law 106-554)
• Under control of OMB
• Applies to all Federal Agencies

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There are No Waivers to Statutory Requirements
O
/
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EC 1165-2-209 Applicability

• Applies to all USACE elements having civil works
  responsibilities.
• Covers all levels of review from basic quality
  control to independent external peer review.
• All feasibility, reevaluation, major
  rehabilitation, project modification,
  post-authorization change studies.
• All CAP projects.
• All design performed for new projects,
  modifications to existing projects, and/or on a
  reimbursable basis.
• All OM plans, reports, manuals, evaluations, and
  assessments etc.

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Review Types

• District Quality Control (DQC)
• Agency Technical Review (ATR)
• Independent External Peer Review (IEPR)
• Policy and Legal Compliance Review
• Conducted throughout the entire study process

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DQC
ATR
Type I IEPR
Type II IEPR
Universe of Civil Works Technical Reviews
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District Quality Control (DQC)

• Review of basic science and engineering products
  focus on fulfilling quality requirements of the
  PMP.
• Managed and conducted in home District by staff
  not directly involved with the work.

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Agency Technical Review (ATR)

• Formerly known as Independent Technical Review
  (ITR).
• In-depth review to ensure proper application of
  regulations, laws, codes, principles and
  professional practices.
• Assess whether analysis presented is technically
  correct and complies with USACE guidance, policy
  and procedures.
• Review work products and assure all parts fit
  together and are presented in a clear manner for
  the public and decision makers.
• Conducted by USACE outside of home District with
  leader outside home MSC.
• ATR documentation (DrChecks) should accompany all
  submittals.
• Documentation of coordination with appropriate
  Centers of Expertise (e.g. relevant PCX, Cost
  Engineering CX, etc).
• PCXs developing Training / Certification Program

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Independent External Peer Review (IEPR)

• Two types
• Type 1 on decision documents
• Type 2 Life and Safety on design and
  construction activities

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Type I IEPR Mandatory Triggers

• Significant threat to human life
• Total Project Cost gt 45M
• Request by State Governor of an affected state
• Any other circumstances the Chief warrants.
• Significant public dispute (size, nature,
  effects)
• Significant public dispute (economics, or environ
  costs, benefits)
• Novel methods, complex challenges,
  precedent-setting methods

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Type I IEPR

• IEPR Administered by the PCXs
• Managed by Outside Eligible Organizations
• Fully Federally Funded

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Type II IEPRSafety Assurance Review

• Applicability
• Flood Risk Management and Storm Damage Reduction
  Projects.
• Any failure poses significant threat to human
  life.
• Safety assurance factors must be considered
  during studies.
• Factors to Consider
• Where failure leads to significant threat to
  human life.
• Novel methods\complexity\ precedent-setting
  models\policy changing conclusions.
• Additional Engineering considerations.
• Chief of Engineers directs.

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Final Policy and Legal Compliance Review

• Washington-level determination that the
  recommendations and supporting analyses comply
  with law and policy.
• Technical reviews are meant to complement policy
  review.
• Policy Review conducted by the OWPR and
  facilitated by the RIT.
• Legal review must be undertaken for AFB, Draft
  Reports, and Final Reports.
• Legal certifications must be provided with Draft
  and Final Report submittals.

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Review Plans

• Stand alone document but component of the Quality
  Management Plan (QMP) in the Project Management
  Plan (PMP).
• Describes the scope and execution of anticipated
  review, including DQC, ATR, IEPR, and Policy and
  Legal Review, for the current and/or upcoming
  phase of work.
• For Type I IEPR, PCX facilitates RP.
• MSC Commander approves the RP to assure that the
  plan is in compliance with EC and the MSC QM and
  that all elements of the command have agreed to
  the review approach.
• Only Deputy Director for Civil Works can approve
  exclusion from IEPR

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Review Plans

• RP anticipates and defines appropriate level of
  review.
• PMP identifies all review requirements,
  processes, costs and schedules as integrated
  features of the overall project execution.
• To the maximum extent practicable, reviews shall
  be scheduled and conducted so as not to cause
  delays in study or project completion. This is
  particularly pertinent in the case of external
  reviews.
• The project budget shall include adequate funds
  for all necessary reviews.
• The project schedule shall provide sufficient
  time for all reviews at the appropriate points in
  the schedule.

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Centers of ExpertiseRoles and Responsibilities

• Planning Technical Centers of Expertise (PCX)
  created in guidance 25 August 2003
• EC 1165-2-209 requires that all Review Plans (RP)
  for decision documents be coordinated with the
  appropriate PCX
• Review Plans are to be approved at the MSC level
  and publicly posted on the Corps web site
• Coordinate and certify/approve models

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Planning Centers of Expertise
David A. Weekly LRH [phone]
Eric W. Thaut SPD [phone]
Jodi Staebell MVD [phone]
Bernard E. Moseby SAM [phone]
Clarke I. Hemphill POA [phone]
Lawrence J. Cocchieri NAD [phone]
Peter H. Shaw SWD [phone]
Sub-Planning Center of Expertise For Small Boat
Harbors
https//kme.usace.army.mil/CoPs/CivilWorksPlanning
-Policy/pcx/default.aspx
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Characteristics of a Good Reviewer

• Strong Technical Background
• Familiar with Principles and Guidelines, WRDA,
  Statutes, and Corps Regulations
• Good Writer and Communicator
• Experience with Many Project Purposes
• Strong Stomach and Thick Skin
• Hard to find, PCXs fielding web based training
  to grow good reviewers

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Avoid These Potential Reviewers Mindset

• I dont like the project - pick it apart
• I wouldnt have done it that way
• You are Trying to Sneak Something by
• Perfection
• Report must get a Nobel Prize for Literature
• What is that District up to now?

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Review Issues

• Review and study teams meet to resolve issues
• District functional chiefs should decide on
  unresolved technical issues
• Policy issues should be forwarded to Division
• Issue Resolution Conferences may be called by
  District, Division, or HQ

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Structure of Comments

• A clear statement of the concern (information
  deficiency or incorrect application of policy or
  procedures)
• Basis of the concern (law, policy, guidance)
• Significance of the concern
• Provide suggested actions needed to resolve the
  concern
• Review Team Leader should ensure there are no
  frivolous, conflicting, or duplicative comments

Kepe EDitorial commints off lyne
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Responding to Comments

• All comments should be recorded in Dr. Checks
• All Comments Require Response
• Actions Taken Should be Clearly Documented in
  Response
• Cite Location in Revised Document
• Document Lessons Learned as Applicable

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