36C26319Q0838-005.pdf

QUALITY ASSURANCE SURVEILLANCE PLAN (QASP)

For: Annual Services for Fargo VAHCS Hazardous Waste Disposal (FY20).

Contract Number:

Contract Description: Provide hazardous, dual, lab pack, and universal waste transport and disposal services of these wastes from the Fargo Veterans Affairs Health Care System (Fargo VAHCS). Services shall include all labor, supplies, materials, tools, equipment, travel, transportation, disposal, documentation and support services required to categorize, package, transport, dispose and document the wastes covered in the Performance Work Statement (PWS). The contractor shall also provide a list back to the Fargo VAHCS for ordering supplies, materials, equipment, etc.

Contractor’s Name: (Hereafter referred to as the contractor).

1. PURPOSE.

This Quality Assurance Surveillance Plan (QASP) provides a systematic method to evaluate performance for the stated contract. This QASP explains the following:

• What will be monitored.

• How monitoring will take place.

• Who will conduct the monitoring.

• How monitoring efforts and results will be documented.

This QASP does not detail how the contractor and any subcontractors accomplish the work. Rather, the QASP is created with the premise that the contractor and any subcontractors are responsible for management and quality control actions to meet the terms of the contract as well as all federal, state and local regulations and laws. It is the Government’s responsibility to be objective, fair, and consistent in evaluating performance.

This QASP is a “living document” and the Government may review and revise it on a regular basis. However, the Government shall review any revisions with the contractor and subcontractors (as needed). Copies of the original QASP and revisions shall be provided to the contractor, subcontractors (as needed) and Government officials implementing surveillance activities.

2. GOVERNMENT ROLES AND RESPONSIBILITIES.

The following personnel shall oversee and coordinate surveillance activities:

a. Contracting Officer (CO) - The CO shall ensure performance of all necessary actions for effective contracting, ensure compliance with the contract terms, and shall safeguard the interests of the United States in the contractual relationship. The CO shall also assure that the contractor receives impartial, fair, and equitable treatment under this contract. The CO is ultimately responsible for the final determination of the adequacy of the contractor’s performance.

Assigned CO:

Organization or Agency: Department of Veterans Affairs.

b. Contracting Officer’s Representative (COR) - The COR is responsible for technical administration of the contract and shall assure proper Government surveillance of contractor and subcontractor performance. The COR shall keep a quality assurance file. The COR is not empowered to make any contractual commitments or to authorize any contractual changes on the Government’s behalf.

Assigned COR:

c. Other Key Fargo VAHCS Government Personnel:

i. Jamie Zettel, Green Environmental Management Systems (GEMS) Program Manager.

3. CONTRACTOR REPRESENTATIVES.

The following employees of the contractor serve as the contractor’s program manager for this contract.

a. Program Manager and Title(s): James B. Engstrom, Chief. EMS

b. Other Key Contractor and Subcontractor Personnel and Title(s):

i.

ii.

4. PERFORMANCE STANDARDS.

Performance standards define desired services. The Government performs surveillance to determine if the contractor and/or subcontractor exceeds, meets or does not meet these standards.

The performance requirements listed in the Performance Work Statement (PWS), includes performance standards. The Government shall use these standards to determine contractor and subcontractor performance and shall compare contractor performance to the Acceptable Quality Level (AQL).

Both contractor and subcontractor performance shall be evaluated using this QASP. However, it shall be the responsibility of the contractor to ensure that they and all subcontractors are meeting the performance requirements and elements of this contract.

Task Indicator Standard AQL Method(s) of Surveillance

Disincentives C h a ra c te ri z a ti o n o f W a s te S tr e a m s

Are all manifests, waste determinations, shipping information, and other data/documentation as applicable, required for the proper execution of this contract being maintained by the Contractor? Are the originals and/or copies being provided to the Fargo VAHCS GEMS Manager or designee?

This process shall be evaluated after all waste has undergone final disposition and all documentation has been received.

95%

Observation, file review and periodic inspection.

Contractor must develop an effective Corrective Action Plan (CAP) to show how and by what date it intends to bring performance up to the required AQL of

95%. The CAP shall be submitted to the COR or designee. The

Fargo VAHCS may either suspend future performance under this contract or terminate the contract if the AQL is not brought up to

95%.

T ra in in g

Has the Contractor made available to the Fargo VAHCS GEMS Manager at least one key staff member as a technical point-of contact to provide technical expertise on topics related to EPA, DOT, State-specific RCRA and other environmental regulations?

This process shall be evaluated throughout the performance of this contract.

95%

Observation, file review and periodic inspection.

Contractor must develop an effective Corrective Action Plan (CAP) to show how and by what date it intends to bring performance up to the required AQL of

95%. The CAP shall be submitted to the COR or designee. The

Fargo VAHCS may either suspend future performance under this contract or terminate the contract if the AQL

D e li v e ra b le s

Has the Contractor provided a current list of all Contractor and subcontractor transfer stations;

treatment, storage and disposal facilities (TSDF), including incineration, autoclaving, wastewater and sludge treatment facilities that shall be utilized during this contract, to include the capacity of these facilities and the waste codes for the waste streams they are permitted to accept by treatment technology? Has the Contractor provided the names, addresses, phone numbers, facsimile numbers, and point-of-contact information for all contractor and/or subcontractor facilities used during the execution of this contract?

This process shall be evaluated throughout the performance of this contract. This shall also Include before, during and after all transportation processes; until all waste has undergone final disposition and all documentation has been received.

95%

Observation, file review and periodic inspection.

Contractor must develop an effective Corrective Action Plan (CAP) to show how and by what date it intends to bring performance up to the required AQL of

95%. The CAP shall be submitted to the COR or designee. The

Fargo VAHCS may either suspend future performance under this contract or terminate the contract if the AQL

D o c u m e n ta ti o n

Has the Contractor and/or subcontractor provided all manifests and documentation that apply to the transport and disposal of wastes covered under this contract by its staff and its subcontractors? Did the Contractor and/or subcontractor furnish properly executed and legible copies of the appropriate manifests and related documentation required to document the safe transport and proper end disposal of all wastes covered under this contract?

This process shall be evaluated throughout the performance of this contract. This shall also Include before, during and after all transportation processes; until all waste has undergone final disposition and all documentation has been received.

95%

Observation, file review and periodic inspection.

Contractor must develop an effective Corrective Action Plan (CAP) to show how and by what date it intends to bring performance up to the required AQL of

95%. The CAP shall be submitted to the COR or designee. The

Fargo VAHCS may either suspend future performance under this contract or terminate the contract if the AQL is not brought up to

95%.

Did the Contractor and/or subcontractor obtain approvals and signatures for each document associated with shipping/transporting of waste from the Fargo VAHCS GEMS Manager or designee, verifying that the Contractor and/or subcontractor has accepted the waste from the Fargo VAHCS and that the waste is being properly transported for disposal? Were these approvals and signatures obtained prior to transportation of all wastes?

Did the Contractor return the signed copies of all shipping/transportation documentation as applicable, to the Fargo VAHCS GEMS Manager or designee within thirty (30) calendar days of when the wastes were transported?

This process shall be evaluated throughout the performance of this contract. This shall also Include before, during and after all transportation processes; until all waste has undergone final disposition and all documentation has been received.

95%

Observation, file review and periodic inspection.

Contractor must develop an effective Corrective Action Plan (CAP) to show how and by what date it intends to bring performance up to the required AQL of

95%. The CAP shall be submitted to the COR or designee. The

Fargo VAHCS may either suspend future performance under this contract or terminate the contract if the AQL

5. INCENTIVES.

The Government shall not use incentives for this contract.

6. METHODS OF QA SURVEILLANCE.

Various methods exist to monitor performance. The COR shall use the surveillance methods listed below in the administration of this QASP.

a. Observation: This can be direct (e.g., visual performance of on-site activities) or indirect (e.g., reviews of emails and other correspondence discussing off-site activities) and occur during any/all of the performance stages of this contract. This performance element can be conducted periodically and/or through 100% surveillance. Performance Standards/Elements listed above utilizing this method:

i. 1. Description of Work Characterization of Waste Streams: m

iv. 2. Training: c

vii. 3. Deliverables: b

viii. 4. Documentation: b, c

b. Periodic Inspection: This can be a formal (i.e., any documented inspection report, visual observation of on-site activities, etc.) or informal (i.e., non-documented observations, data/document reviews, etc.)

and occur during any/all of the performance stages of this contract. This performance element can be conducted periodically and/or through 100% surveillance. Outcomes are evaluated on a periodic basis. Inspections may be scheduled (e.g., daily, weekly, monthly, etc.) or unscheduled, as needed/required. Performance Standards/Elements listed above utilizing this method:

i. 1. Description of Work Characterization of Waste Streams: m

iv. 2. Training: c

vii. 3. Deliverables: b

viii. 4. Documentation: b, c

c. File Review: This can be a formal (i.e., any documented review of reports, emails, price lists, manifests, etc.) or informal (i.e., non-documented reviews of reports, emails, price lists, manifests, etc.) and occur during any/all of the performance stages of this contract. This performance element can be conducted periodically and/or through 100% surveillance. File reviews are conducted on a periodic basis. The reviews may be scheduled (e.g., daily, weekly, monthly, etc.) or unscheduled, as needed/required. Performance Standards/Elements listed above utilizing this method:

i. 1. Description of Work Characterization of Waste Streams: m

iv. 2. Training: c

vii. 3. Deliverables: b

viii. 4. Documentation: b, c

7. RATINGS.

Metrics and methods are designed to determine if Contractor and/or subcontractor performance exceeds, meets, or does not meet a given standard and acceptable quality level (AQL). A rating scale shall be used to determine a positive, neutral, or negative outcome. The following ratings shall be used:

Yes – The service has been completed according to contractual and legal requirements (i.e., positive rating).

No – The service has not been completed according to contractual and legal requirements (i.e., negative rating).

N/A – Not Applicable or not evaluated during the surveillance period (i.e., neutral rating).

8. DOCUMENTING PERFORMANCE.

a. Acceptable Performance: The Government shall document positive and negative performance. Any report may become a part of the supporting documentation for any contractual action.

b. Unacceptable Performance: When unacceptable performance occurs, the COR shall inform the contractor. This will normally be in writing unless circumstances necessitate verbal communication. In any case the COR shall document the discussion and place it in the COR file.

When the COR determines formal written communication is required, the COR shall prepare a Contract Discrepancy Report (CDR), and present it to the contractor's program manager.

The Contractor shall acknowledge receipt of the CDR in writing (e.g., email, registered mail, etc.). The CDR will specify if the Contractor is required to prepare a corrective action plan to document how the Contractor and/or subcontractor shall correct the unacceptable performance and avoid a recurrence.

The CDR will also state how long after receipt the contractor has to present this corrective action plan to the COR.

The Government shall acknowledge receipt of the CDR, in writing (e.g., email, registered mail, etc.).

The Government shall review the contractor's corrective action plan to determine acceptability. If acceptable, the Government shall acknowledge acceptability of the corrective action in writing (e.g., email, registered mail, etc.).

Any CDRs may become a part of the supporting documentation for any contractual action deemed necessary by the CO.

9. FREQUENCY OF MEASUREMENT.

a. Frequency of Measurement: During contract performance, the COR will periodically analyze whether the negotiated frequency of surveillance is appropriate for the work being performed.

b. Frequency of Performance Assessment Meetings: The COR shall meet with the contractor and any subcontractors on an as-needed basis, and every time there is a waste shipment, in order to assess performance.

Signature – Contractor Program Manager Date

Signature – Contracting Officer’s Representative Date