A.03.23 QASP_ENV-23-0038.pdf

i

Quality Assurance Surveillance Plan FY23 USAG Ansbach CCAN104 and CCAN126

Groundwater Remedial Action

ENV-23-0038

Prepared By

U.S. Army Corps of Engineers, Europe District Environmental Division

Konrad Adenauer Ring 39 Wiesbaden, 65187 Germany

7 July 2023

FY23 USAG Ansbach CCAN106 and CC126 Groundwater Remedial Action QASP ii

CONTENTS

1.0 OVERVIEW

1.1 Introduction

1.2 Purpose

2.0 ROLES AND RESPONSIBILITIES OF QUALITY ASSURANCE OFFICIALS

2.1 Contracting Officer

2.2 Contracting Officer Representative

2.3 Technical Expertise and Subject Matter Experts

3.0 PERFORMANCE ASSESSMENT

3.1 Evaluation Areas AND RATINGS CRITERIA

3.2 Performance Assessment Process

3.2.1 Army-Approved Delays

3.3 Overall Recommendation

4.0 MONITORING METHODS

4.1 100% Inspection

4.2 Periodic Inspection

4.3 Customer Feedback

4.4 Additional Surveillance Activities

4.5 Key Milestones and Deliverables TO BE MONITORED

4.6 Performance Standards

5.0 SURVEILLANCE DOCUMENTATION

5.1 Quality Assurance Monitoring Form

5.2 Corrective Action Process

5.3 KO and COR Roles in Surveillance Process

5.4 Technical Quality Assurance Monitoring

6.0 PROGRESS PAYMENTS

6.1 Acceptable Performance

6.2 Unsatisfactory Performance

LIST OF TABLES

Table 1 – Subject Matter Experts Table 2 – Example Evaluation Areas & Ratings Criteria Table 3 – Key Milestones and Deliverables by Evaluation Areas Table 4 – Specific Evaluation Criteria for Established Key Milestones/Deliverables

LIST OF ATTACHMENTS

Attachment A: Quality Assurance Monitoring Form Attachment B: Corrective Action Form

ACRONYMS & ABBREVIATIONS

APP Accident Prevention Plan CENAU Corps of Engineers Europe District COR Contracting Officer’s

Representative CORT COR Tracking CPARS Contractor Performance

Assessment Reporting System KO Contracting Officer

PMP Project Management Plan QAMF Quality Assurance Monitoring Form QA Quality Assurance QASP Quality Assurance Surveillance Plan SME Subject Matter Experts SOW Scope of Work

1.0 OVERVIEW

1.1 INTRODUCTION

This Quality Assurance Surveillance Plan (QASP) sets forth the procedures and methods the U.S. Army Corps of Engineers (USACE) Contracting Officer’s Representative (COR) will use in evaluating the technical and quality performance of the Contractor in accordance with the terms and conditions of the FY23 Ansbach CCAN104 and CCAN126 Groundwater Remedial Action Scope of Work (SOW) dated 6 July 2023. A copy of the signed final QASP will be furnished to the Contractor to be informed of the methods the COR will use in evaluating performance of this contract. The signed final QASP will also be uploaded to the COR Tracking (CORT) Tool.

1.2 PURPOSE

The purpose of the QASP is to ensure the performance of specific activities and the completion of project milestones are accomplished in accordance with all requirements set forth in the SOW and outlined in the Project Management Plan (PMP). This QASP describes the mechanism for documenting noteworthy accomplishments or discrepancies for work performed by the Contractor. Information generated from the COR’s surveillance activities will directly feed into performance discussions with the Contractor and the Contractor Performance Assessment Reporting System (CPARS). The intent is to ensure the Contractor performs in accordance with the metrics set forth in the contract documents, the Army receives the quality of services required in the contract, and the Army only pays for acceptable services received.

The QASP is intended to accomplish the following:

• Define the role and responsibilities of participating USACE officials.

• Define the key milestones, deliverables, and standards that will be assessed.

• Describe the surveillance methodology that will be employed by USACE in assessing the

Contractor’s performance.

• Describe the surveillance documentation process and provide copies of the forms USACE will use in evaluating the Contractor’s performance.

• Outline quality assurance procedures to be employed by the Government during performance of this task order.

• Define Evaluation Areas, including: Quality, Schedule, Management, Regulatory

Compliance, and other areas (as applicable).

• Define Performance Standards for key milestones, deliverables, and standards, including:

Exceptional, Very Good, Satisfactory, Marginal, and Unsatisfactory.

• Outline corrective action procedures.

• Describe requirements for showing progress prior to submitting invoices.

2.0 ROLES AND RESPONSIBILITIES OF QUALITY ASSURANCE OFFICIALS

2.1 CONTRACTING OFFICER

The Contracting Officer (KO) has overall responsibility for overseeing the Contractor’s performance. The KO is responsible for the day-to-day monitoring of the Contractor’s performance in the areas of contract compliance, and contract administration; reviewing the COR’s assessment of the Contractor’s performance; and resolving all differences between the COR’s assessment and the Contractor’s assessment of performance. It is the KO that assures the Contractor receives impartial, fair, and equitable treatment under the contract. The KO is ultimately responsible for the final determination of the adequacy of the Contractor’s performance. The KO for this contract is [TO BE DETERMINED] at the CENAU Europe District Headquarters Office. Questions for the KO should be directed to the assigned CENAU Contracting Specialist, [TO BE DETERMINED] at 0611-9744-XXXX.

2.2 CONTRACTING OFFICER REPRESENTATIVE

The COR is responsible for technical administration of the project and assures sufficient CENAU surveillance of the Contractor’s performance. The COR is responsible for monitoring, assessing, recording, and reporting on the technical performance of the Contractor on a day-to-day basis. The COR for this contract is Darren Newton at the CENAU Europe District Headquarters Office, +49 611-9744- 2151, darren.newton@usace.army.mil.

2.3 TECHNICAL EXPERTISE AND SUBJECT MATTER EXPERTS

The KO and COR may call upon the technical expertise of other CENAU or Army employees.

These subject matter experts (SME) may be called upon to review technical documents and products generated by the Contractor. For this contract, the following SMEs have been identif ied:

TABLE 1 – Subject Matter Experts CENAU Project Manager Darren Newton USAG Ansbach Stephan Haas

If additional SMEs are identif ied as work progresses, the QASP will be modified to capture this information.

3.0 PERFORMANCE ASSESSMENT

3.1 EVALUATION AREAS AND RATINGS CRITERIA

The Contractor’s performance will be evaluated by assessing the key milestones and deliverables according to the standards of Quality, Schedule, Management, and Regulatory Compliance. Other Evaluation Areas can be included at the discretion of the COR and Project Manager and will be provided to the Contractor in a QASP update. Each Evaluation Area is rated as Exceptional, Very Good, Satisfactory, Marginal, or Unsatisfactory. Table 2 includes example indicators for assessing Evaluation Areas and provides ratings definitions.

TABLE 2 – Example Indicators for Evaluation Areas and Rating Definitions

EVALUATION AREAS & EXAMPLE INDICATORS

Quality • Product performance relative to contract’s performance parameters

• Performance in terms of contract’s quality objectives

• Use quantitative indicators wherever possible

• Contractor’s management of the quality control program

• Quality of the work or service

Schedule • Timeliness of the Contractor against the completion of the contract, task orders, milestones, delivery schedules, and administrative requirements

• Contractor’s adherence to the required delivery schedule, that contributes to or affects the scheduled variance

• Adverse actions such as the assessment of liquidated damages or issuance of Cure Notices, Show Cause, and Delinquency Notices are indicators of problems which may have resulted in variance to the contract schedule and should, therefore, be noted in the evaluation

• Adequacy of Initial Progress Schedule

• Submission of Required Documentation

• Adherence to Approved Schedule

• Submission of Updated & Revised Progress Schedules

• Resolution of Delays

Management • Integration and coordination of activity

• Problem identification

• Corrective action plans

• Reasonable and cooperative behavior

• Customer satisfaction

• Subcontract management

• Program management

• Management of key personnel

Regulatory Compliance with U.S.

and Host Nation regulations

• Compliance with regulations and codes

• Financial

• Environmental

• Labor o Correction of Noted Deficiencies o Compliance with Labor Laws and Regulations with Specific Attention to the Davis-Bacon Act and o Equal employment requirements o Payrolls properly completed and submitted

• Safety o Adequacy of safety plan o Correction of noted deficiencies o Implementation of safety plan

• Other Reporting requirements in the contract

EVALUATION AREA RATINGS DEFINITIONS*

Exceptional Performance meets contractual requirements and exceeds many to the Government’s benefit.

The contractual performance of the element or sub-element being assessed was accomplished with few minor problems for which corrective actions taken by the contractor was highly effective. To justify an exceptional rating, identify multiple significant events and state how they were of benefit to the Government. A singular benefit, however, could be of such magnitude that it alone constitutes an exceptional rating. Also, there should have been NO significant weaknesses identified.

Very Good Performance meets contractual requirements and exceeds some to the Government’s benefit.

The contractual performance of the element or sub-element being assessed was accomplished with some minor problems for which corrective actions taken by the contractor was effective. To justify a very good rating, identify a significant event and state how it was a benefit to the Government. There should have been NO significant weaknesses identified.

Satisfactory Performance meets contractual requirements.

The contractual performance of the element or sub-element being assessed contains some minor problems for which corrective actions taken by the contractor appear or were satisfactory. To justify a satisfactory rating, there should have been only minor problems, or major problems the contractor recovered from without impact to the contract. There should have been NO significant weaknesses identified. Per DOD Policy, a fundamental principle assigning ratings is that contractors will not be assessed a rating lower than satisfactory solely for not performing beyond the requirements of the contract.

Marginal Performance does not meet some contractual requirements.

The contractual performance of the element or sub-element being assessed reflects a serious problem for which the contractor has not yet identified corrective actions. The contractor’s proposed actions appear only marginally effective or were not fully implemented. To justify marginal performance, identify a significant event in each category that the contractor had trouble overcoming and state how it impacted the Government. A marginal rating should be supported by referencing the management tool that notified the contractor of the contractual deficiency (e.g., management, quality, safety or environmental deficiency report or letter).

Unsatisfactory Performance does not meet most contractual requirements and recover is not likely in a timely manner.

The contractual performance of the element or sub-element contains a serious problem(s) for which the contractor’s corrective actions appear or were ineffective. To justify an unsatisfactory rating, identify multiple significant events in each category that the contractor had trouble overcoming and state how it impacted the Government. A singular problem, however, could be of such serious magnitude that it alone would constitute an unsatisfactory rating. An unsatisfactory rating should be supported by referencing the management tools used to notify the contractor of the contractual deficiencies (e.g., management, quality, safety or environmental deficiency report or letter).

*The guidelines provided for issuing ratings are subjective in nature, and these ratings will be supported by the weight of evidence documented during the Government's surveillance efforts.

3.2 PERFORMANCE ASSESSMENT PROCESS

If a deliverable is rated as being unsatisfactory for Quality or Regulatory Compliance at the time that the approved SOW deadline for the milestone expires, the Contractor may receive an unsatisfactory rating for Schedule, unless there is an Army-approved delay that extends the deliverable/milestone. The rating will only be in effect during that rating period and will not necessarily influence subsequent ratings.

3.2.1 Army-Approved Delays

At the discretion of the COR, the performance standard of Schedule may not be monitored due to Army-approved delays. Quality Assurance Monitoring Forms (QAMF) will track and report Army-approved Delays.

3.3 OVERALL RECOMMENDATION

In lieu of an overall rating, the Contractor will either be recommended or not recommended for similar future requirements.

4.0 MONITORING METHODS

4.1 100% INSPECTION

All key milestones and deliverables will be evaluated through 100% inspection by onsite inspection or document review. The CENAU Project Manager will document performance for each completed milestone or deliverable prior to payment, as described in Section 5.0.

4.2 PERIODIC INSPECTION

At the CENAU Project Manager’s discretion, periodic inspections will be conducted to evaluate progress toward key milestones and deliverables. This will include Quality Assurance (QA) inspections of safety, f ield work, chemical data packages, etc. by a government representative.

The CENAU Project Manager may also complete a periodic progress inspection if they believe deficiencies exist which must be addressed prior to milestone or deliverable completion. While corrective action or re-performance will be required, if necessary, the Contractor will not be financially penalized for unacceptable performance recorded in periodic progress reports, provided that final performance evaluation of the milestone or deliverable is deemed acceptable.

4.3 CUSTOMER FEEDBACK

Contractor performance feedback will be obtained through periodic inquiries by the CENAU Project Manager with project stakeholders. The purpose of these inquiries is be to supplement the other forms of evaluation and to also provide the Contractor with constructive criticism or recognition for the project deliverables or milestones completed. Customer feedback received will be thoroughly validated to ensure it relates to the requirements of the contract and will be used in a prudent manner by the COR. Customer feedback will also be solicited in the form of a concurrence letter by the Contractor from appropriate stakeholders for key deliverables.

4.4 ADDITIONAL SURVEILLANCE ACTIVITIES

Additional Government surveillance activities may include, but are not limited to, the following:

• Review and approval of meeting minutes from Kickoff Meetings

• Review of data deliverables

• Oversight of f ield work activities

• Review of uploaded electronic deliverables

• Review of the Contractor’s quality control documentation.

• Review of the Contractor’s safety records

4.5 KEY MILESTONES AND DELIVERABLES TO BE MONITORED

Table 3 includes the evaluations areas to be assessed for each key milestone and deliverable.

Table 3 – Key Milestones and Deliverables to be Monitored Milestone/Deliverable* Quality Schedule Management Regulatory

Compliance (incl. Safety)

Task 1: Planning Documents, including QAP and

APP

X X X X

Task 2 - Treatment Area Pad Installation X X X X Task 3 - Power Connection Building 5801 to Pad X X X X Task 4 - Water Permit X X X X Task 5 - CCAN104 Remedial Action TS3 Installation and Start-up

X X X X

Task 6 - Remedial Action Treatment System 3 Operation and Maintenance

X X X X

Task 7 - CCAN104 Groundwater Monitoring X X X X Task 8 - Reporting CCAN104 X X X X Task 9 - CCAN126 Building 5801 Remedial Action TS2 Installation and Start-up

X X X X

Task 10 - Remedial Action Treatment System 2 Operation and Maintenance

X X X X

Task 11 - Reporting CCAN126 Building 5801 X X X X Task 12: Ancillary Items (Meeting Minutes, including KOM, etc)

X X X

Option Year 1 and 2: see Tasks 1-12 X X X X

4.6 PERFORMANCE STANDARDS

The Contractor’s performance will be evaluated by assessing the key milestones and deliverables above according to the standards of Quality, Schedule, Management, and Regulatory Compliance (which includes Safety). In addition, the Contractor’s performance will be evaluated for the standard of Safety during any fieldwork. For each of these performance standards, the COR will assign one of f ive ratings of the Contractor’s performance: Exceptional, Very Good, Satisfactory, Marginal, or Unsatisfactory, as shown in Table 3.

Table 4 – Specific Evaluation Criteria for Established Key Milestones and Deliverables

Performance Standard

Exceptional Very Good Satisfactory Marginal Unsatisfactory

Quality Draft and Final deliverables are of excellent quality, approved as submitted, or with no substantive comments limited to grammar, spelling, or terminology.

Army audit finds that the data collected or the work performed exceeds the requirement of the SOW. No

Draft deliverables are of high quality and comments are mostly minor.

Final deliverables are approved after one (1) round of comments on the Draft through acceptance of response to comments table and back check of Final report against original comments. No further revisions are required.

Draft deliverables are of acceptable quality with only a few comments identifying major weaknesses.

Final deliverables are approved after two (2) rounds of comments on Draft. No further revisions are required.

Draft deliverables are of poor quality with a significant number of comments identifying major weaknesses or deficiencies.

Final deliverables require more than two (2) rounds of comments on Draft before being approved.

(e.g., changes are required to

Draft deliverables are of very poor quality and are rejected for resubmittal without comment. Final deliverables did not comply with contract requirements, or one or more document versions required more than three (3) rounds of comments

Performance Standard

Exceptional Very Good Satisfactory Marginal Unsatisfactory deficiencies noted

Army audit of work does not identify any deficiencies that compromise the quality of the data collected or work performed.

Army audit of work identifies deficiencies that do not compromise the quality of the data collected or work performed and can be corrected.

the Final document due to inadequate incorporation of comments).

Army audit of work identifies deficiencies that compromise the quality of the data collected or work performed but were corrected.

before being approved.

Army audit of work identifies deficiencies that compromise the quality of the data collected or work performed and cannot be corrected.

Schedule Contractor Achieves milestone more than 60 days ahead of schedule, per criteria established in the SOW and this

QASP.

Contractor Achieves milestone less than 60 days but more than 30 days ahead of schedule, per criteria established in the SOW and this

QASP.

Contractor achieves milestone according to the schedule, per criteria established in the SOW and this QASP.

Contractor achieves milestone more than 30 days but less than 60 days behind schedule (unless the COR notes Army delay), per criteria established in the SOW and this QASP.

Contractor achieves milestone more than 60 days behind schedule (unless the COR notes Army delay), per criteria established in the SOW and this QASP.

Management All personnel proposed by the contractor were assigned to the project.

Zero (0) instances of resource management issues creating a negative impact to the activity.

All personnel proposed by the contractor were assigned to the project.

No more than one (1) instance of resource management issues creating a negative impact to the activity.

All personnel proposed by the contractor were assigned to the project.

Informal poor performance feedback on conduct of personnel is provided by the COR but are corrected.

No more than two (2) instances of resource management issues creating a negative impact to the activity.

All personnel proposed by the contractor were assigned to the project.

Formal letter of poor performance feedback on conduct of personnel is provided by the COR but are corrected.

No more than three (3) instances of resource management issues creating a negative impact to the activity.

All personnel proposed by the contractor were assigned to the project.

Written request from CENAU requesting removal of assigned personnel for poor performance or notification of poor performance is provided by the COR and is not corrected.

More than three

(3) instances of resource management issues creating a negative impact to the activity.

Performance Standard

Exceptional Very Good Satisfactory Marginal Unsatisfactory

Regulatory Compliance (includes Safety)

Contractor obtains concurrence on deliverables from the PDT.

No significant safety deficiencies are reported during QA inspection of fieldwork. No lost time accidents or injuries are recorded during the fieldwork.

Contractor obtains concurrence on deliverables from the PDT.

No more than one (1) serious safety deficiencies are reported during QA inspection of fieldwork. If any serious safety deficiency is noted during the project, appropriate investigation, corrective action, implementation, and written verification of the corrective action are provided to the Army. No lost time accidents or injuries are recorded during the fieldwork.

Contractor obtains concurrence on deliverables from the PDT.

No more than two (2) serious safety deficiencies are reported during QA inspection of fieldwork. If any serious safety deficiency is noted during the project, appropriate investigation, corrective action, implementation , and written verification of the corrective action are provided to the Army. No lost time accidents or injuries are recorded during the fieldwork.

Contractor obtains concurrence on deliverables from the PDT.

No more than three (3) serious safety deficiencies are reported during QA inspection of fieldwork. If any serious safety deficiency is noted during the project, appropriate investigation, corrective action, implementation, and written verification of the corrective action are provided to the Army. No more than one lost time accident or injury is recorded during the fieldwork.

Contractor does not obtain concurrence on deliverables from the PDT.

More than three

(3) serious safety deficiencies are reported during QA inspection of field activities, or a serious safety deficiency is reported but not properly investigated and corrected, or two or more lost time accidents or injuries is recorded during field activities

5.0 SURVEILLANCE DOCUMENTATION

5.1 QUALITY ASSURANCE MONITORING FORM

The COR or designee will use the QAMF (Attachment A) to record evaluation of the Contractor’s performance for each payment milestone or final deliverable in accordance with the methodology described in this QASP. The CENAU Project Manager must substantiate, through narratives on the form, all ratings. Performance at the acceptable level is expected from the Contractor. At a minimum, the evaluation form will indicate actual and scheduled delivery times and number of reviews required to achieve the final product.

5.2 CORRECTIVE ACTION PROCESS

When a key milestone or deliverable receives a marginal or unacceptable rating, within 15 calendar days the Contractor shall explain in writing to the CENAU COR why performance was marginal or unacceptable, how performance will be returned to acceptable levels, and how recurrence of the problem will be prevented in the future. The Contractor shall use the corrective action form as part of this process (Attachment B). The CENAU COR will review the proposed corrective action with the customer and CENAU Project Manager as necessary to determine if it will be accepted.

5.3 KO AND COR ROLES IN SURVEILLANCE PROCESS

The CENAU Project Manager will provide the COR and KO with copies of all completed QAMFs. When appropriate, the COR or KO may investigate further to determine if all the facts and circumstances surrounding the event were considered in the CENAU Project Manager opinions outlined on the form. The COR or KO will immediately discuss any unacceptable rating with the Contractor’s Program Manager to assure that corrective action is promptly initiated. At the end of the contract performance period, the CENAU Project Manager will prepare a written report for the COR and KO summarizing the overall results of the surveillance of the Contractor’s performance during the contract. This report will become part of the formal QA documentation. The CENAU Project Manager will maintain a complete QA file. This file will contain copies of all performance evaluation forms and any other related documentation. The CENAU Project Manager will forward these records through the COR and to the KO at termination or completion of the contract.

5.4 TECHNICAL QUALITY ASSURANCE MONITORING

In general, all work will be evaluated in terms of how well the requirements of the task order are satisfied, the extent to which the work performed follows the approach found in the contractor’s technical proposal or implements the decision of Technical Project Planning, and clarity of documentation. At the discretion of the COR or KO, other government officials may be asked to evaluate a particular deliverable or set of deliverables. The results of all Technical Quality Assurance Monitoring will be documented using the QAMF.

6.0 PROGRESS PAYMENTS

6.1 ACCEPTABLE PERFORMANCE

The Contractor is required to submit progress updates which include the percent completion for each task required in the SOW. Full payment for a task will be provided upon verification of overall acceptable performance as indicated on the QAMF or through communications with the Contractor. The Contractor may provide an invoice to the CENAU Project Manager after receipt of a QAMF indicating acceptable performance or after agreement on progress percent completion is made. The Contractor may submit an invoice if a QAMF or communication of approval is not provided to the Contractor within 14 days of submitting a progress update.

6.2 UNSATISFACTORY PERFORMANCE

If a milestone or deliverable receives an unsatisfactory rating for either the Quality or Regulatory Compliance performance standard, re-performance is required until the deliverable receives an acceptable rating. This re-performance is required regardless of cost or schedule constraints that may result from the unsatisfactory performance, unless the KO has opted to terminate the contract.

QASP Approval:

Name Date Darren Newton, Contracting Officer’s Representative

ATTACHMENT A: QUALITY ASSURANCE MONITORING FORM

Project Name: FY23 USAG RP, CCKL168 GWM and CCKL164 RI and GWM Contract Number, Task/Delivery Order Number: TBD: W912GB21-D-0044-48

Customer Name and Point of Contact: Claudia Weber, Environmental Engineer

DPW, Environmental Management Division

USAG RP

Comm: +49 (0) 611-143-541-4701

E-mail: Claudia.Weber1.LN@mail.mil

Contractor Name and Point of Contract: TBD

Milestone, Deliverable or Standard:

Survey Period (enter dates of field oversight or NA):

Method of Surveillance:

Narrative Discussion of Contractor Performance:

Corrective Action Required? ☐ Yes (if yes, see corrective action form) ☐ No

I certify that I have checked the quantities covered by this bill or estimate: that the work was actually performed; that the quantities are correct and consistent with all previous computations as actually checked; that the quantities and amounts are wholly consistent with the requirements of the contract or other instrument involved.

Printed Name Signature Date Title

ATTACHMENT B: CORRECTIVE ACTION FORM

Project Name Date Form Completed

Date Problem First Discovered

Time Problem First Discovered

Name and Contact Information of Person Completing Form

Description of the Requirement or Specification

Reason for Corrective Action

Suggested Corrective Action

Description of Impact of Corrective Action on the Project (e.g.

scope, schedule)

Estimated Cost Impact of Corrective Action

Corrective Action Plan Approval

Contractor Printed Name/Signature/Date:

USACE Contractive Officer’s Representative Printed Name/Signature/Date:

Follow-Up of Corrective Action Implementation (date and description of implementation)

Printed Name/Signature/Date

3.3 Overall Recommendation