ATTACHMENT 10 - QASP CA Env Services 1.6.2025.pdf

Quality Assurance Surveillance Plan for

Environmental Services

California

DFSP Norwalk and El Toro Pipeline Release Site DFSP San Pedro

SPE603-25-R-0503

January 6, 2025

Performance Work Statement January 4, 2024

DFSPs Norwalk and San Pedro, California

TABLE OF CONTENTS

Paragraph Description Page 1 Purpose 3 2 Authority 3 3 Roles and Responsibilities 3 4 Performance and Surveillance 4

Appendix A Service Delivery Summary Table 9 Appendix B Customer Complaint Record 12 Appendix C DD Form 2772, Contract Discrepancy Report 13 Appendix D Surveillance and Performance Monitoring (SPM) Smart Form 15 Appendix E Sample Quarterly COR Report 16

1. Purpose

1.1. This Quality Assurance Surveillance Plan (QASP) is a Government-developed document used to determine if the Contractor’s performance meets the performance standards contained in the Performance Work Statement (PWS). The QASP establishes procedures on how this assessment/inspection process will be conducted. It provides the detailed process for contract oversight:

• What will be monitored

• How monitoring will take place

• Who will conduct the monitoring

• How monitoring efforts and results will be documented

1.2. The Contractor is responsible for implementing and delivering performance that meets the standards outlined in the PWS. The QASP provides the structure for the Government’s surveillance of the Contractor’s performance to ensure it meets the standards outlined in the PWS. It is the Government’s responsibility to be objective, fair and consistent in evaluating Contractor performance.

1.3. This QASP is a living document. Flexibility in the QASP is required to allow for an increase or decrease in the level of surveillance necessary based on Contractor performance.

All surveillance documentation as a result of this QASP will be marked, “Controlled Unclassified Information (CUI)”.

1.4. The Government may provide a copy of the QASP to the Contractor to facilitate open communication. In addition, the QASP should recognize that unforeseen or uncontrollable circumstances might occur that are outside the control of the Contractor.

1.5. The QASP should be a tool to help ensure early identification and resolution of performance issues to minimize impact on mission performance.

2. Authority

2.1. Authority for issuance of this QASP is provided under Part 46 of the Federal Acquisition Regulation (FAR), Inspection of Services clauses, which provide for inspection, acceptance and documentation of the service called for in the contract or order. This acceptance is to be executed by the Contracting Officer or a duly authorized representative.

3. Roles and Responsibilities

3.1. Government and Contractor personnel have a part in ensuring the Contractor performance meets the standards set forth in the PWS and applicable documents. Government personnel involved in overseeing and coordinating surveillance activities are identified below.

3.2. Contracting Officer (CO). The CO is the person who can bind the Federal Government of the United States to this contract. This is limited to the scope of authority delegated to the CO.

3.3. Contracting Specialist (CS). The CS supports the CO and provides government oversight.

3.4. Contracting Officer’s Representative (COR) – The COR is responsible for providing ongoing technical surveillance of the Contractor’s performance. The COR uses the QASP to conduct the surveillance process. The purpose is to ensure that the Contractor meets the performance standards contained in the contract. The COR is responsible for reporting early identification of performance problems to the CO. The COR is required to provide an annual performance assessment to the CO which will be used in documenting past performance. The QASP is the primary tool for documenting Contractor performance. The COR is not empowered to make any contractual commitments or to authorize any contractual change on the Government’s behalf.

4. Performance and Surveillance

4.1. Contract Surveillance

4.1.1. The Contractor, not the Government, is responsible for operations, management, and contract compliance actions to successfully meet the terms of the contract. The goal of the QASP is to ensure Contractor performance is effectively monitored and documented.

4.1.2 The COR uses the methods contained in this QASP to assess the Contractor’s compliance with contract requirements. Also, the COR must maintain a professional, non-adversarial relationships with the CO and the Contractor, which enables positive, open and timely communications. The foundation of this relationship is built upon objective, fair, and consistent COR evaluations of Contractor performance against contract requirements. Toward this end, periodic requirements for evaluations are provided, and a standard reporting format is used.

Additional spot checks are allowed and recommended to prevent lapses in performance between periodic inspections, enable early identification of discrepancies, and allow for additional focus on problem areas. However, excessive inspection must be avoided, as this can adversely affect the working relationships and ultimately Contractor and COR effectiveness.

4.2. Service Delivery Summary

4.2.1. The Service Delivery Summary Table (Appendix A) incorporates the major task subareas of the PWS as the basis for evaluation of the Contractor performance.

4.2.2. The Surveillance Method and Performance Measure show how the COR will accumulate data relating to the specific measures to assess overall Contractor performance.

4.2.3. For Utilities, the Acceptable Quality Level (AQL) must be performed at least at the minimum level of service required to successfully meet the performance requirements.

4.3. Measuring Performance

4.3.1. Discrepancies in Contractor performance generally fall into one of the three categories below which are used to differentiate between levels of impact of the shortfall.

4.3.1.1. Critical Nonconformance. In accordance with (IAW) FAR 46.101, critical nonconformance means a nonconformance that is likely to result in hazardous or unsafe conditions for individuals using, maintaining, or depending upon the supplies or services; or is likely to prevent performance of a vital agency mission. Examples include, but are not limited to:

A. Failure to adhere to policies, procedures, or regulations which would have been the proximate cause of or did result in a reportable safety incident, unsafe operation, injury, or accident.

B. Failure to adhere to policies, procedures, or regulations which would have been the proximate cause of or did result in a reportable environmental mishap or notice of violation.

C. Failure to adhere to policies, procedures, or regulations which would have been the proximate cause of or did result in a security incident or violation.

D. Failure to provide and implement appropriate corrective actions for previously documented critical nonconformance within specified timeframes.

4.3.1.2. Major Nonconformance. IAW FAR 46.101, major nonconformance means a nonconformance, other than critical, that is likely to result in failure of the supplies or services or to materially reduce the usability of the supplies or services for their intended purpose. Examples include, but are not limited to:

A. Failure to adhere to policies, procedures, or regulations resulting in customer impact.

B. Failure to meet a safety, environmental, or security Performance Measure not otherwise identified as a critical nonconformance.

C. More than second-time repeat minor nonconformance within 12 month period.

D. Failure to provide and implement appropriate corrective actions for previously documented major nonconformance within specified timeframes.

E. Second-time repeat minor nonconformance discrepancies within 12 month period.

4.3.1.3. Minor Nonconformance. IAW FAR 46.101, minor nonconformance means a nonconformance that is not likely to materially reduce the usability of the supplies or services for their intended purpose, or is a departure from established standards having little bearing on the effective use or operation of the supplies or services. Examples include, but are not limited to:

A. Failure to adhere to policies, procedures, regulations or generally accepted practices or to meet a Performance Measure not otherwise addressed as a critical or major nonconformance.

B. First time repeat minor nonconformance discrepancies within 12 month period.

C. Failure to provide and implement appropriate corrective actions for previously documented minor nonconformance within specified timeframes.

4.3.2 Quarterly Performance Rating Definitions

When evaluating the quality of Contractor’s performance, the following overall performance ratings and criteria will be used. The factors used for each criterion are specified in the Service Delivery Summary (SDS) Table in Appendix A and in Section 4.0 of the PWS.

Performance Rating

Criteria (Quarterly)

Exceptional No critical or major nonconformance; All Performance Measures met;

and more than one Performance Measure exceeded

Very Good No critical or major nonconformance; All Performance Measures met; and one Performance Measure exceeded

Satisfactory No critical or major nonconformance; All Performance Measures met;

and no Performance Measure exceeded

Marginal One critical or major nonconformance; and/or one Performance Measure not met; one uncorrected minor nonconformance within 12 months

Unsatisfactory More than one critical or major nonconformance; and/or more than one Performance Measure not met; more than one uncorrected minor nonconformance within 12 months

4.3.3 Annual Contractor Performance Assessment Rating

The COR will use the quarterly inspections as the basis for providing the annual Contractor performance evaluation in the Contractor Performance Assessment Reporting System (CPARS). The below table provides a rationale for the COR’s CPARS ratings which should be justified by the quarterly ratings.

Rating

Criteria (Annual)

Exceptional All quarterly reports rated Exceptional, Very Good, or Satisfactory with more than half rated Exceptional

Very Good Does not meet the requirement for Exceptional; all quarterly reports rated Satisfactory or above with more than half rated Very Good

Satisfactory Does not meet the requirement for Very Good; all quarterly reports rated Marginal or above with more than half rated Satisfactory

Marginal Does not meet the requirement for Satisfactory; all quarterly reports rated Marginal or above

Rating

Criteria (Annual)

Unsatisfactory Does not meet the requirement for Marginal; one or more quarterly reports rated Unsatisfactory

4.3.2. Performance Reporting

4.3.2.1. Discrepancies or nonconformance may be identified through a variety of means including periodic or random checks by the COR, outside agency inspections or observations, and stakeholder complaints. Early observation, notification, and correction is vital to ensuring mission support is maintained.

4.3.2.2. The COR will evaluate contractor performance of PWS requirements identified in the PWS and Appendix A below. The COR will prepare the quarterly report and provide to the Contracting Specialist/Officer by entry into Surveillance and Performance Monitoring (SPM) if available or via email not later than the fifth working day of the first month of the following quarter unless otherwise directed by the Contracting Specialist/Officer.

4.3.4.2.1. The COR should not wait to document findings from periodic or random inspections in a quarterly report but should make every effort to notify the CO, CS, Contractor and other appropriate personnel as soon as possible to enable prompt, appropriate corrective actions to be taken. Initial verbal notification is acceptable with follow-up email notification to provide minimum documentation and tracking. All nonconformance should be documented on appropriate forms and subsequently included in the COR quarterly report.

4.3.4.2.2. Minor nonconformance and subsequent corrective actions to be taken will be documented by the COR in the appropriate performance assessment section of the quarterly COR report.

4.3.4.2.3. Critical and Major Nonconformance and subsequent corrective actions to be taken will be documented by the COR on DD Form 2772, Contract Discrepancy Report (Appendix C) and forwarded to the Contracting Officer for approval upon occurrence. No alternate forms may be used. These will subsequently be documented in the appropriate performance assessment section of the quarterly COR report.

4.3.4.3. Outside agency inspection findings should be provided to the COR for validation and incorporation in the quarterly COR report. Required responses should be developed by the contractor and routed through the COR to the Contracting Officer prior to release to the inspecting agency.

4.3.4.4. As customer service is a primary focus of the contractor performance, customer complaints are taken very seriously. Any customer who observes unacceptable services, whether poorly, incompletely, or not performed, should immediately contact the COR. If the deficiency requires immediate correction, a phone call may be necessary. When a complaint is received, the

COR validates the complaint by checking the PWS. The COR must evaluate the complaints on a case-by-case basis. If any Government action or lack of action caused unacceptable performance, the complaint is not valid. If the complaint is valid, a Customer Complaint Record (Appendix B) and DD Form 2772 will be annotated by the COR, and the Contracting Officer will be notified.

4.3.4.5. For continued nonconformance or lack of implementation by the contractor of corrective action, the COR should continue to document discrepancies as noted above and notify the Contracting Officer if the situation warrants for further action.

APPENDIX A

Service Delivery Summary (SDS) Table

A1.1. The Service Delivery Summary Table below incorporates the major task subareas from Section 4.0 of the PWS as the basis for evaluation of the Contractor performance.

PERFORMANCE

STANDARDS

PWS

SECTION

PERFORMANCE THRESHOLD METHOD OF

SURVEILLANCE

PS 1: Meets all milestones IAW the timeline outlined in the Integrated Master Schedule (IMS).

4.1.1.1 Excellent: Objective achieved 1 quarter, or more, in advance.

Very Good: Objective achieved 1 month in advance.

Successful: Objective met on-time.

Meets/Does Not Meet: Objective achieved 1 quarter later and beyond.

Review of Monthly Progress Reports, Periodic Inspection and/or Customer Feedback

PS 2:

Communication with relevant stakeholders resulting in timely identification and solution of impediments to successful project execution.

4.1 4.2.3 4.2.6 4.4.1.9 4.4.1.10 4.4.1.11 4.4.2.1 4.4.2.2 4.4.2.5 4.4.3

Meets/Does Not Meet: No more than two (2) validated late responses per year throughout the contract POP

Periodic (quarterly) Inspection and/or Customer Feedback (as received)

PS 3: Timely submission of proposals, design packages and other primary documents IAW the timeline outlined in the IMS or as required by the PWS.

4.1.1.1 6.1

Meet/Does not Meet: No more than two

(2) validated late responses per year throughout the contract POP.

If the contractor fails to complete any portion of this task the contractor will forfeit one half of a payment for each 30-day period (or portion thereof) that it is out of compliance and be responsible for any additional cleanup requirements.

100% inspection by DLA and state and regulatory reviewers as well as Customer Feedback (as received)

PS 4: Submit high quality Reports and Plans

4.2.5 Meet/Does not Meet: No more than one

(1) significant rewrite per quarter.

Examples of significant rewrite include but are not limited to: revisions triggering an additional full deliverable review by either DLA or a regulatory

Periodic (quarterly) surveillance and/or Customer Feedback (as received). For example, errata significant enough to require additional

STANDARDS

PWS

SECTION

PERFORMANCE THRESHOLD METHOD OF

SURVEILLANCE

agency; multiple (greater than three) revisions to correct procedures, activities, or statements that are not in accordance with policy, guidance, or regulation; correction of a flaw that directly affects the overall success of the project, invalidates conclusions, or severely compromises technical defensibility of reported results; edit of misrepresented or omitted information that substantively influences decision making; and/or correction of deficiencies or problems indicating systemic quality problems with potential to adversely impact project outcomes.

No more than one (1) errata requested or required to submit to a regulatory agency per quarter (e.g. regulator or public stakeholder asks for an errata sheet be uploaded to California’s GeoTracker) upload.

PS 5: Maintain Remedial Systems at Optimal Operations

4.2 Meet/Does not Meet: Contractor shall

keep the systems in operation as established in the remedial action work plan or applicable operations & maintenance plan, for at least 90% of the time on a rolling 2-month average. If the contractor fails to maintain this level of operation, the contractor will forfeit one half of a payment for each 30-day period (or portion thereof) that it is out of compliance. This threshold may not apply if any delivery order issued that directly holds the requirement in abeyance. If a month is held in abeyance, then the rolling average will be based on the last 2-months of requirement.

Review of Monthly Progress Reports, Periodic Inspection and/or Customer Feedback (as received).

In the event of a failure of a key system component where the system may be shut down for longer than 72 hours, the Contractor should immediately notify DLA a lengthy delay is possible.

Review of correspondence (as received)

PS 6: Conduct all compliance tasks

IAW DOD, DLA,

4.3 Excellent: Significantly reduced (10% or

greater) costs or level of effort for the Government; or, improved the

Periodic (quarterly) surveillance and/or

STANDARDS

PWS

SECTION

PERFORMANCE THRESHOLD METHOD OF

SURVEILLANCE

State, and regional regulations.

Conduct all permitted activities IAW permit requirements.

compliance program/project within a complex regulatory/stakeholder environment.

Very Good: Reduced costs or level of effort for the Government; or, maintained compliance program/project within a complex regulatory/stakeholder environment.

Meets/Does Not Meet: Conducted all tasks with Compliance requirements with no more than two (2) late or missed notifications.

received)

PS 6: Conduct all permitted activities IAW permits.

Conduct all compliance tasks

IAW DOD, DLA,

State, and regional regulations.

4.4 Excellent: Improved conditions that

significantly reduced potential liabilities (cost or otherwise) to the Government;

or, Contractor addressed an issue raised and took measures to address root cause (e.g. neighbor noise complaint).

Very Good: Improved conditions that reduced potential liabilities to the Government; or, conducted a facility maintenance task on short or no notice.

Meets/Does Not Meet: Conducted facility maintenance tasks with no more than two (2) verified complaints of late or insufficient repairs.

Periodic (quarterly) surveillance and/or received)

APPENDIX B

Customer Complaint Record

CUSTOMER COMPLAINT RECORD

DATE/TIME OF COMPLAINT

SOURCE OF COMPLAINT

ORGANIZATION BUILDING NUMBER INDIVIDUAL PHONE NUMBER

NATURE OF COMPLAINT

CONTRACT REFERENCE

VALIDATION

DATE/TIME CONTRACTOR INFORMED OF COMPLAINT

ACTION TAKEN BY CONTRACTOR

RECEIVED/VALIDATED BY

APPENDIX C

DD Form 2772 – Contract Discrepancy Report

APPENDIX D

SPM Smart Form (Example Below)

APPENDIX E

*SAMPLE*

Quarterly COR Report attached to SPM Smart Form

Contract #: SPE603-25-D-xxxx

Contractor: XXX

Rated Period of Performance Dates: 1/1/2025 through 3/31/2025

Evaluation Areas Rating Quality: Exceptional Schedule: Very Good Cost Control: N/A N/A Management: Very Good Small Business Subcontracting: Very Good Regulatory Compliance: Exceptional Other Areas:

(1) : N/A

(2) : N/A

(3) : N/A

Assessing Official Comments:

QUALITY: Comments supporting the Quality Rating.

SCHEDULE: Comments supporting the Schedule Rating.

MANAGEMENT: Comments supporting the Management Rating.

SMALL BUSINESS SUBCONTRACTING: Contractor sub-contracted XX% of their work to small-businesses, exceeding the goal of XX%.

REGULATORY COMPLIANCE: Comments supporting the Regulatory Compliance rating.

Contracting Officer’s Representative

Jane Doe Environmental Protection Specialist DLA Energy LEVB 571-767-xxxx

X

Contracting Officer's Representative

* Ratings are IAW FAR 42.1503 (Table 42-1) Exceptional; Very Good; Satisfactory; Marginal; Unsatisfactory

**Provide details for services received above or below a satisfactory rating. A quality written narrative is important, as it not only supports the rating assigned but also becomes the basis for CPARS assessments and other contracting actions.