01. SOW - Filter Testing.pdf

Statement of Work HEPA/ULPA Filter Testing Program

U.S. Department of Energy

C. 01 BACKGROUND ON THE DOE FILTER TESTING PROGRAM

High Efficiency Particulate Air (HEPA) or Ultra Low Penetration Air (ULPA) filters can have a vital role in protecting workers, the public and the environment during an accidental internal release of radioactive material in a Department of Energy (DOE)/National Nuclear Security Administration (NNSA) nuclear facility. For this reason, the integrity and performance of HEPA filters is vital in postulated accident conditions. However, to ensure that HEPA filters installed in nuclear facilities will perform as intended, DOE maintains a contract with an independent facility to conduct visual inspections and performance testing. Only filters that pass the independent tests are forwarded for use in DOE/NNSA nuclear facilities.

C.02 SCOPE

The scope of this Statement of Work (SOW) includes:

• Receipt of HEPA or ULPA (if the ULPA option is exercised) filters, visual inspection, and proper storage pending performance tests.

• Conduct of penetration and resistance tests.

• Preparation of monthly inspection and test reports.

• Preparation of monthly filter status reports.

• Monthly photos of visual physical damage discovered during filter inspection

• Repacking and shipment of tested filters to purchaser or to manufacturer, as directed by purchaser.

• Preparation of semi-annual reports to DOE.

• Training and qualification of personnel.

• Quality assurance program.

• Worker safety and health program.

• Facility and equipment maintenance program.

• Contingency plan.

• Document control and records management.

• Annual management assessments.

C. 03 PURPOSE AND OBJECTIVES

Purpose: The purpose of this Statement of Work is to provide DOE with independent (i.e., non-manufacturer) testing of HEPA for use in DOE’s nuclear facilities. ULPA filters may be tested if the Government provides a minimum of 120 days’ notice of their intent to exercise the corresponding option to begin ULPA filter testing.

**Independent (i.e., non-manufacturer) testing of HEPA filters shall be performed during each year (Base Year and all Option Years) of the contract.

**Independent (i.e., non-manufacturer) testing of ULPA filters shall be performed during each Option Year that is exercised by the Government but not to begin any earlier than the first option year.

Objectives: The contractor is expected to meet the following general objectives:

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a) Establish and operate a HEPA filter testing facility, meeting all requirements in accordance with this SOW, including adequate throughput capacity to meet the needs of DOE/NNSA nuclear facilities. If an option is exercised to include ULPA filter testing, the Contractor will provide the ability to test ULPA filters meeting all requirements in accordance with this SOW, including adequate throughput capacity to meet the needs of DOE/NNSA nuclear facilities.

b) Ensure that all facility personnel, management and staff, are trained and qualified for assigned roles and responsibilities.

c) * MANDATORY MINUMUM REQUIREMENT MUST establish and rigorously implement a quality assurance program meeting the requirements of DOE O 414.1D, Quality Assurance.

d) Maintain the facility to ensure worker safety and continuous operations.

e) Deliver complete and accurate reports to DOE in a timely manner as required by this SOW.

f) * MANDATORY MINUMUM REQUIREMENT

MUST conform to the performance testing requirements of the latest versions of ASME AG- 1, Code on Nuclear Air and Gas Treatment as described in DOE-STD-3025-2007, Quality Assurance Inspection and Testing of HEPA Filters;

g) Develop and maintain a contingency plan to develop a testing program that conforms to the performance testing requirements of the latest versions of IEST-RP-CC007: TESTING ULPA FILTERS/ IEST-RP-CC001: HEPA AND ULPA FILTERS within 120 days of advance notice from DOE of exercising an option to include ULPA testing;

h) Securely store and protect all documents and records related to this contract from hazards and deterioration. A contingency plan for records recovery should be documented. The DOE O 243.1B, Records Management Program, shall be implemented where applicable;

i) Adequately control access to personnel records and DOE stored records.

C. 04 DEFINITIONS

Definitions for technical terms used in this SOW and its supporting documents may be found in:

• DOE Order 414.1D, Quality Assurance;

• DOE Guide 414.1-1C, Management and Independent Assessments Guide;

• DOE Guide 414.1-2B, Quality Assurance Program Guide;

• DOE Guide 414.1-4, Safety Software Guide for Use with 10 CFR 830, Subpart A, Quality

Assurance Requirements, and DOE O 414.1C, Quality Assurance;

• DOE-STD-3020, Specification for HEPA Filters Used by DOE Contractors;

• DOE-STD-3025, Quality Assurance Inspection and Testing of HEPA Filters

• ASME AG-1, Code on Nuclear Air and Gas Treatment;

• ASME NQA-1, Quality Assurance Requirements for Nuclear Facility Applications;

C. 05 APPLICABLE REQUIREMENTS AND STANDARDS

(a) The contractor must comply with the requirements of DOE-STD-3025, Quality Assurance Inspection and Testing of HEPA Filters.

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(b) The contractor must use laser particle counting systems discussed in ASME AG-1 in place of the requirement for use of a Q-107 or Q-76. In addition, an additional aerosol, 4 centistoke polyalphaolefin (PAO) is a preferred aerosol as discussed in ASME AG-1 Section FC.

(c) When testing HEPA filters, the contractor must comply with the applicable performance testing requirements of ASME AG-1, Code on Nuclear Air and Gas Treatment for HEPA filters.

(d) When testing ULPA filters upon exercising the corresponding option period, the contractor must comply with the applicable performance testing requirements of IEST-RP-CC007:

Testing ULPA Filters and IEST-RP-CC001: HEPA And ULPA Filters.

(e) The contractor must comply with the requirements of DOE Order 414.1D, Quality Assurance.

(f) The contractor must comply with the requirements of DOE Order 243.1B, Records Management Program.

C.06 OPERATIONS AND PROCEDURES

(a) When conducting independent inspection and performance testing of HEPA filters, the contractor must implement DOE-STD-3025 Quality Assurance Inspection and Testing of HEPA Filters

(b) When conducting independent inspection and performance testing of ULPA filters, the contractor must implement IEST-RP-CC007: Testing ULPA Filters and IEST-RP-CC001:

HEPA and ULPA Filters

(c) HEPA and ULPA filters are purchased by DOE facilities from various manufacturers in accordance with specifications provided in the purchase order. Filters are shipped from the manufacturer to the Filter Test Facility (FTF) for the required inspection and performance testing. Filters passing inspection and performance testing are then repackaged and shipped from the FTF to the DOE facility as directed by the organization purchasing the filters.

Filters rejected are returned to the manufacturer or shipped on to the purchaser as directed by either the purchase order or the DOE Contracting Officer Representative.

(d) The arrangement for filter shipments and the cost for shipping filters is the responsibility of the purchaser or manufacturer.

(e) The contractor must perform filter inspections and testing according to the following process flow or as directed by DOE:

1. A DOE or NNSA site orders filters from a filter manufacturer.

2. The DOE or NNSA site provides an advance copy of the purchase order directly to the

FTF concurrent with providing the manufacturer the original purchase order.

3. For those filters that arrive at the FTF and that the FTF has already received its advance copy of the purchase order, the FTF shall receive the filter shipment and conduct a visual inspection.

4. For those filters that arrive at the FTF and that FTF has no advance copy of its purchase order, then FTF does not accept the shipment from the shipper.

5. Filters not passing visual inspections because of manufacturing defects are repackaged and returned to the manufacturer according to shipping instructions provided by the purchaser.

6. Filters with incorrect labeling and no other defects are to be performance tested. If the filter passes performance testing, the FTF will follow its quality assurance program, U.S. Department of Energy document and tag the labeling issues appropriately, repackage the filter and ship it to the purchaser in accordance with the purchase order instructions. The DOE or NNSA site will resolve the labeling issue in accordance with its quality assurance program.

7. Performance testing of all HEPA filters is to be consistent with the most recent requirements of DOE-STD-3025, ASME AG-1 or other DOE authorized testing method.

8. If the contingency plan is invoked and the corresponding option period exercised, performance testing of all ULPA filters is to be consistent with the most recent requirements of IEST-RP-CC007 and IEST-RP-CC001.

9. All filters passing visual inspections and performance testing are to be repackaged by the FTF and forwarded per the instructions in the purchase order.

10. All filters failing performance testing, and those failing visual inspection due to manufacturing defect, are to be repackaged by the FTF and forwarded per the instructions in the purchase order.

11. A copy of the inspection and testing reports for each filter are to be forwarded to the purchasers of the filters and to DOE’s Office of Nuclear Safety. The FTF must retain the original inspection and testing reports as federal records in accordance with the requirements of DOE Order 243.1B, Records Management Program.

(f) The contractor is responsible for obtaining any necessary permits and providing HEPA/ULPA filter inspection and testing services in compliance with applicable federal, state and local laws and regulations.

C.07 FACILITY AND EXPECTED CAPACITY

(a) HEPA filters used in DOE or NNSA facilities are defined in DOE-STD-3020 or ASME AG-

1. The typical ratings of HEPA filters sent to the FTF are from 15 cfm to 2000 cfm.

(b) The typical ratings of ULPA filters used in DOE or NNSA facilities expected at the FTF are below 20 cfm.

(c) The contractor must have the capability of receiving, storing, inspecting, performance testing, repackaging, and shipping filters as specified in DOE-STD-3025. Filters received having complete documentation are to be tested within 10 calendar days of receipt. Expected annual filter throughput for filters is an average of 300 to 400 filters per month.

(d) * MANDATORY MINUMUM REQUIREMENT The contractor MUST be able to develop and maintain a contingency plan to address such issues as power outages, equipment breakdowns, spare parts availability, correction of audit deficiencies, and personnel problems. This plan must be provided to DOE for approval within 90 days of contract award.

C.08 QUALITY ASSURANCE PROGRAM

(a) The contractor shall develop a quality assurance program that meets the applicable requirements of DOE O 414.1D, Quality Assurance. The contractor shall adopt the appropriate version of ASME NQA-1 as the consensus standard for its quality assurance program. The contractor should use DOE G 414.1-2B, Quality Assurance Program Guide to assist in their development of an acceptable quality assurance program.

(b) The contractor shall submit its quality assurance program to DOE for approval within 90 days of being awarded a DOE Contract.

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(c) The contractor shall start work using its quality assurance program only after DOE has approved it formally.

(d) The contractor shall review its quality assurance program annually and update it is as necessary. The contractor shall submit a summary of the results of its annual review of the quality assurance program to the DOE Technical Monitor within 30 days after completion of the review. All updates or revisions to the contractor’s quality assurance program shall be approved by DOE prior to implementing the update or revision.

(e) If the contractor utilizes a subcontractor, a vendor, or a supplier, the contractor must ensure that its quality assurance program requirements has been followed for the item or service received from the subcontractor, vendor, or supplier. The contractor is to immediately supply DOE with information on request of the contractor’s use of a subcontractor, a vendor, or a supplier.

C.09 TRAINING AND QUALIFICATIONS OF FACILITY STAFF

(a) The contractor must establish written procedures in accordance with the DOE Order 414.1D that include the training and qualification requirements as specified in DOE-STD-3025.

(b) Prior to the commencement of operations and continuously updated throughout the life of the contract, the contractor must provide DOE with complete written documentation showing that any personnel performing and supervising filter inspection and performance testing meet the training requirements specified in DOE-STD-3025.

C. 10 PROTECTION OF EQUIPMENT, FACILITY AND WORKERS

(a) The contractor is liable and expected to take all reasonable measures to protect the filter testing facility, filters onsite in condition received, its equipment, and its workers from harm or damage.

(b) Extended process interruption caused by fire, serious equipment malfunctions, and quality assurance failures may be grounds for contract termination.

(c) The contractor MUST be able to properly calibrate and maintain equipment. Calibration records must be readily available to the DOE Technical Monitor on request.

(d) The FTF staff are to regularly inspect for potential hazards that could be detrimental to the facility such as unnecessary accumulation of combustible materials or improper electrical practices

(e) Within 90 days of contract award, the contractor must prepare and submit to DOE for approval a Worker Safety and Health Program required by 10 CFR Part 851, Subpart B.

C. 11 REPORTS TO DOE AND DOCUMENT RETENTION

(a) The contractor MUST be able to provide the reports specified in DOE-STD-3025 to DOE on a timely basis. These reports must use a version of Microsoft Office that is compatible with DOE systems. For scanned documentation, the contractor must use Adobe Acrobat in such a manner to keep file sizes under 10 megabytes. The contractor shall ensure that all scanned documentation is legible and centered correctly.

(b) The contractor must meet the reoccurring reporting requirements shown in the attachment to this SOW.

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(c) Monthly inspection/test reports and monthly status reports of all filters at the facility with copies of all FTF inspection and FTF test reports are due on the 7th of the following month.

Errors in the reports are limited to an annual maximum of 0.1% in the reporting data. Any additional errors found in the monthly reports are subject the contractor’s monthly payments to deductions equivalent to the costs incurred by the DOE’s Office of Nuclear Safety in conducting additional reviews of the data reported. Any delays in reporting require approval of the Technical Monitor or considered a breach of contract.

(d) Photos that demonstrate the major or unusual defects of filters are to be provided with the monthly reports.

(e) Semiannual reports MUST be provided to the Technical Monitor no later than April 30 and October 31 of each year. Since the semiannual reports are derived directly from the monthly reports, there should be no errors in the reporting data. Any errors found in the semiannual reports are subject the contractor’s monthly payments to deductions equivalent to the costs incurred by the DOE’s Office of Nuclear Safety in conducting additional reviews of the data reported. Any delays in reporting require approval of the Technical Monitor or considered a breach of contract.

(f) In the event of errors are being found in the reporting data by the Technical Monitor, the contractor must document the errors in its quality assurance program (e.g., corrective action system) and submit the corrections within 24 hours after ensuring that no other similar errors exist in the same submission of reporting data. Actions to preclude similar errors occurring in future reports shall be integrated into the contractor quality assurance program via the DOE approved revision process. The contractor must track and trend these errors and take progressive corrective action to keep them below the 0.1% error rate.

(g) Complete and auditable files of all test and inspection records, calibration records, personnel qualification records, and quality assurance records are to be retained. These records are the property of DOE for review throughout the contract period and must be surrendered at the end of the contract.

(h) All documents and records related to this contract must be stored securely and protected from hazards and deterioration in accordance with the contractor’s quality assurance program.

(i) Access to personnel records and FTF related records must be adequately controlled to prevent unauthorized access.

C.12 DOE INSPECTIONS AND AUDITS

(a) The contractor must support onsite inspections and audits by DOE and provide all requested information related to the requirements of this SOW. Requested information may include evidence of compliance with and violations of work procedures, federal, state, and local laws and regulations.

(b) Onsite inspections will be conducted at such time and in such manner as deemed appropriate by all involved parties.

(c) DOE will conduct an audit within six months of contract award to verify that the contractor is implementing its DOE approved quality assurance program, Worker Safety and Health Program, the applicable requirements of DOE-STD-3025 and this SOW.

(d) The FTF shall be subject to additional DOE audits on a periodic basis not to exceed one audit every 3 years throughout the contract. DOE will also perform an audit at the end of contract to verify implementation of the applicable requirements during the closeout of the contract.

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C.13 COMMUNICATION

The DOE Technical Monitor will meet with contractor management personnel as necessary (in person or by phone link) to discuss FTF performance and any issues that have arisen. The contractor will respond to sporadic or ad hoc requests for additional information on FTF activities within 24 hours of receiving the request. The contractor will notify the DOE Technical Monitor of all difficulties with any shipment by email or by direct telephone contact. Any future reasonable DOE requests for minor changes to data reporting after contract award will require contractor acceptance with no additional cost. The FTF management staff may consider participating in the conference calls held with DOE and NNSA site representatives on HEPA or ULPA filter issues.

The FTF will immediately notify the Technical Monitor by email and phone call of any external parties requesting access to the FTF excluding the contractor staff and associated subcontractors.

The FTF shall keep a log of all visitors from external parties.

The FTF must maintain a list of site personnel contacted with their contract information.

The contractor MUST provide and maintain adequate contact information for the Contracting Officer Representative and the Technical Monitor to ensure communications with the Contractor are not hindered.

Filters are to be tested on a first in first out basis pending all necessary documentation has been received for the shipment. Changes in testing priority are to be approved by the DOE Technical Monitor.

Testing of any filter purchased by a DOE site will take priority over any other request for filter testing services at the FTF.

C.14 TRANSITION MANAGEMENT

It is incumbent upon all contractors participating in contracts at DOE to understand the highly collaborative nature of working at the Department; the Contractor shall exhibit an understanding of this imperative on day 1 of the period of performance. A designated Contracting Officer’s Representative (COR) and the federal program manager will assist with the transition. Technical Monitors (TM) will also be available to collaborate with the transition-in Contractor on transition activities. The COR is the only individual with delegated authority from the CO. TMs have no delegated authority from the CO.

The transition-in Contractor shall be responsible for scheduling a series of meetings with the COR, the transition-out Contractor, and other stakeholders in order to solidify transition arrangements. The transition-in Contractor shall develop and implement a ninety (90)-day Transition Plan that is tailored for DOE operations, and specific to the requirements of this contract. The Contractor shall ensure that the Department’s mission business is not deterred due to gaps in service.

The Contractor’s transition arrangements for this contract shall include:

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• The Contractor shall identify issues and risks, and ensure stakeholders reach a complete understanding of what is required to avoid service disruptions or substandard performance as a result of these issues and risks.

• The Contractor shall reach agreement on the people, process, timelines, and milestones for all deliverables.

The transition period shall extend ninety (90) calendar days from the date of award. During the transition period, the transition-in Contractor shall host daily and weekly meetings with DOE stakeholders to communicate the status of transition tasks and their corresponding milestones, along with a report of issues and the associated plans of action to correct those issues.

U.S. Department of Energy

Attachment

Reoccurring Reporting Requirements

Contracting Officer (A) Address: TBD

Contracting Officer Representative (B)

Address: AU-71

Technical Monitor (C)

Address: AU-32

Reporting Requirements

Submittal Requirements Frequency Distribution

Vouchers/Invoices (SF 1034) e-mail and original Monthly A/B

FTF Test and Inspection Reports e-mail Monthly A/B/C

Filter Test Reports e-mail Monthly A/B/C

FTF Filter Status Reports e-mail Monthly A/B/C

Semi-Annual Test Reports e-mail Semi-Annually A/B/C