Attachment B - Quality Assurance Surveillance Plan.pdf

Quality Assurance Surveillance Plan

For

AIR EMISSIONS (STACK) TESTING

April 2024

COR

Kristi Cavanaugh

DATE BEP

CONTRACTING

OFFICER

Daryl Stewart

DATE

10/20/2023

SUMMARY OF REVISIONS

Revision Dated

Revision page(s) number

Content Position Name

7/26/2023

Revision 1 COR

Kristi Cavanaugh

TABLE OF CONTENTS

Subject Page Number

1. Overview 4

2. Description of Services/Supply/Product 4

3. Roles and Responsibilities 4

4. Contract Quality Requirements 5

5. Government Surveillance 6

6. Non-Conforming Performance 6

7. Data Analysis 7

8. Acceptance of Services 7

9. COR Status Report 7

10. COR/Quality Assurance Surveillance Files 7

11. QASP Changes 7

1. Overview.

1.1. Purpose. The purpose of this Quality Assurance Surveillance Plan (QASP) is to identify the methods and procedures the Government will use to ensure it receives the services under this contract as identified in the Performance Work Statement (PWS).

1.2. Intent. The intent of this QASP is to: 1) ensure Contractor performance meets or exceeds contract terms, conditions and specifications; 2) hold the Contractor accountable for quality control; and 3) encourage the Contractor to take appropriate steps to control and improve quality.

Accordingly, the Government will perform surveillance on the contract in accordance with this QASP, but reserves the right to monitor the contract in any manner necessary, at any times necessary, and at all places necessary to ensure that the rendered services conform to contract requirements. The Government also reserves the right to perform quality assurance at the Subcontractor level and perform quality assurance at the contractor's place of business, if applicable. Resolution of non-conforming services discovered at the Subcontractor level will be addressed with the prime Contractor.

2. Description of Services.

2.1. Scope of Work. The DC Department of the Energy & Environment (DOEE) has issued air permits for the nickel and chromium plating lines (Title V), and these permits require that new emissions compliance tests be completed. Testing will require collection of samples in accordance with U.S. Environmental Protection Agency (EPA) methods. Samples will be collected from exhaust ducts after the pollution control scrubbers that are installed on the nickel and chromium plating lines. The Contractor shall provide all personnel, equipment, tools, materials, vehicles, supervision, and other items and services necessary to perform air emissions compliance testing on the nickel electroforming and chrome electroplating lines located at BEP’s District of Columbia Facility. Testing must be performed in accordance with permit requirements and applicable EPA regulations, using appropriate test methods.

2.2. Type of Contract. The government will award a Firm-Fixed Price contract.

3. Roles and Responsibilities.

3.1. Government.

3.1.1. Contracting Officer (CO). The CO is the only person with the authority to enter into, administer, and or terminate contracts, and make related determinations and findings on behalf of the Government. Note: The only individual who can legally bind the Government.

3.1.2. Contracting Officer’s Representative (COR). The (COR) will be identified by separate letter. The COR monitors all technical aspects of the contract and assists in contract administration. The COR is authorized to perform the following functions: assure that the Contractor performs the technical requirements of the contract: perform inspections necessary in connection with contract performance: maintain written and oral communications with the Contractor concerning technical aspects of the contract: issue written interpretations of technical requirements, including Government drawings, designs, specifications: monitor Contractor's performance and notifies both the Contracting Officer and Contractor of any deficiencies;

coordinate availability of Government furnished property, and provide site entry of Contractor personnel. A letter of designation issued to the COR, states the responsibilities and limitations of the COR, especially with regard to changes in cost or price, estimates or changes in delivery dates. The COR is not authorized to change any of the terms and conditions of the resulting order.

3.1.3. Contract Specialist.

3.2 Contractor.

The contractor will perform all work in accordance with the performance works statement (PWS). The Government shall not exercise any supervision or control over the contract service providers performing the services in the contract. Such contract service providers shall be accountable solely to the Contractor who, in turn is responsible to the Government. Contractor employees performing services under this order will be controlled, directed, and supervised at all times by management personnel of the Contractor. Contractor management will ensure that employees properly comply with the performance work standards outlined in the performance work statement. Contractor employees will perform their duties independent of, and without the supervision of, any Government official. The tasks, duties, and responsibilities set forth in the contract may not be interpreted or implemented in any manner that results in any contractor employee creating or modifying Federal policy, obligating the appropriated funds of the United States Government, overseeing the work of Federal employees, providing direct personal services to any Federal employee, or otherwise violating the prohibitions set forth in Parts 7.5 and 37.1 of the Federal Acquisition Regulation (FAR). The Government will control access to the facility and will perform the inspection and acceptance of the completed work.

4. Contract Quality Requirements.

4.1. Contractor’s Quality Control Program. The Contractor’s quality control program is the means by which he assures himself that his work complies with the requirement of the contract.

The Contractor shall ensure services are performed in accordance with this PWS. The Contractor shall identify, prevent, and ensure non-recurrence of defective services.

4.2. Government Quality Assurance. The Government shall evaluate the Contractor’s performance under this contract in accordance with this QASP. This plan is primarily focused on what the Government must do to ensure that the Contractor has performed in accordance with the performance standards. It defines how the performance standards will be applied, the frequency of surveillance and minimum acceptable defect rate(s).

5. Government Surveillance.

5.1. Methods of Surveillance. The following Methods of Surveillance will be utilized in monitoring the Contractors’ performance:

5.1.1. 100% Inspection Reserved for the highest risk areas where consequence of failure is high (i.e. life or limb are threatened) or there is likelihood of mission failure.

5.2. Surveillance Schedule. A Surveillance Schedule will be created each month utilizing the, COR Surveillance Schedule, Attachment 3. The schedule is “FOR OFFICIAL USE ONLY” and is not releasable to anyone other than authorized Government personnel. A copy of the Surveillance Schedule will be filed and will become part of the CORs file.

5.3. Surveillance Instructions/Checklists. Surveillance Checklists, Attachment 4, will be utilized and completed when surveillances are conducted.

5.4. Surveillance Documentation. The applicable Surveillance Checklist(s) will be completed when/as Surveillances are conducted. Completed Surveillance Checklist(s) will be filed in CORs file. The file will have ready access to the BEP Office of Acquisition.

6. Non-Conforming Performance. Non-conformance occurs when a Contractor fails to meet Contract or Task Order terms, conditions and/or specifications. All instances of non-conformance will be documented and the Contractor will be notified. Resolution of non-conformance discovered at the Subcontractor level will be addressed with the prime Contractor.

Non-conformance is classified as either: Level I (Minor); Level II (Major); or Level III (Critical).

6.1. Level I (Minor). Level I non-conformance is not likely to materially reduce the usability of services for their intended purpose or is a departure from established standards having little bearing on completing the contract requirement. Minor non-conformances can usually be corrected on the spot and can be issued to the Contractor through either a verbal or written Contract Discrepancy Report (CDR). However, the Government is still required to document verbal Level I CDRs. The COR may issue verbal Level I CDRs directly to the appropriate level of Contractor management. The COR will notify the CO as soon as practical when a verbal Level I CDR is issued and document them in their Monthly Reports. If the non-conformance cannot be corrected on the spot, the Contractor shall be given a suspense date to correct the deficiency. The CO will issue and sign written Level I CDRs, Attachment 5.

6.2. Level II (Major). Level II non-conformance is likely to result in failure of the services to meet contract requirements. Also, repeated discrepancies, a large number of documented Level I CDRs and trends indicating failure of the Contractor’s quality control program can be classified as Level II CDRs. The CO issues all Level II CDRs in writing, Attachment 5. The COR will notify the CO as soon as practical when a major non-conformance is identified.

6.3. Level III (Critical). Level III non-conformances result in hazardous or unsafe conditions due to the manner in which the services are performed; prevent or impact a vital agency mission as a result of performance; or are for repeated or uncorrected Level II CDRs. The Contracting

Office Director or Deputy Director issues written Level III CDRs. The COR is responsible for notifying the CO immediately upon discovery of a critical non-conformance.

6.4. Documenting CDRs. Documentation, as a minimum, will include: the Contract or Task Order number; reference to the specific contract requirement; the specific discrepancy to the requirement; where it was discovered; the date and time it was discovered; Contractor representative who was notified; and the suspense date for Contractor response/corrective action.

6.5. Tracking and Resolving CDRs. All CDRs, verbal and written, regardless of issuer will be included in the COR’s Monthly Report. The COR and CO shall track CDRs to ensure the Contractor identifies and takes appropriate corrective action to the root cause and the specific non-conformance is corrected within the required timeline. The CO will make a final written determination of the Government’s remedies if the non-conformance is not corrected by the Contractor after receiving notice and a reasonable opportunity to correct the work.

7. Data Analysis. Data Analysis will be performed to identify trends in cost, schedule and/or performance risks. The results of Data Analysis will be documented in COR Status Reports and may be used to make adjustments to surveillance schedules, increase or decrease surveillance, if deemed appropriate. Negative trends noted using Government data/observations could result in issuing the Contractor a Contract Discrepancy Report. Trends noted using Contractor data will not result in a CDR unless the Contractor is not addressing the negative trend.

8. Acceptance of Services. When all services have been deemed acceptable and there is documented objective quality evidence to support acceptable performance the COR will accept the services provided and authorize payment of the Contractor. This is accomplished by approving the Contractor’s Receiving Reports via IPP.

9. COR Status Report. COR Status Reports will be submitted on a Monthly basis to the Contracting Officer. COR Status Reports will provide a synopsis of the Contractors performance for the inclusive dates of the report. The synopsis will contain a summary of: surveillances performed; Customer Feedback, if any; CDRs, if any; an analysis of the Contractors performance; recommended adjustments to surveillance schedules; and any other pertinent contract information. Completed Surveillance Checklists and CDRs, if any, will be included as attachments to COR Status Reports or uploaded separately in the Miscellaneous Documents Section of the CORs’ Online file.

10. COR/Quality Assurance Surveillance Files. The official COR/Quality Assurance Surveillance File will be maintained by the COR.

11. QASP Changes. This QASP is a living document and, as such, may be changed as needed based on Data Analysis (trends), contract modifications, etc. The COR will send any recommended changes to the Contracting Officer for approval and the Contracting Officer must approve all changes.

Technical Exhibit 1

Performance Requirements Summary (PRS)

Attachments:

C. Customer Complaint Record D. Surveillance Checklists E. Contract Discrepancy Report

Attachment 1 Performance Requirements Summary (PRS)

The contractor services requirements are summarized into performance objectives that relate directly to mission essential items. The performance threshold describes the minimum acceptable levels of service required for each requirement. These thresholds are critical to mission success. Government surveillance of contractor performance is not limited to the Performance Objectives as outlined in this PRS. The Government reserves the right to conduct compliance surveillance of any contractual requirement of this acquisition.

Performance Objective

Performance Standard Performance Threshold

Method of Surveillance

PRS# 1. The contractor shall provide Project Timeline IAW Section 5.1.1 of PWS.

Services provided within required timeline.

100% satisfactory and timely completion

100% inspection by COR

PRS# 2. The contractor shall provide 1st Draft Test Protocol IAW Section 5.1.3 of PWS.

Services provided within required timeline.

1st Draft Test Protocol shall be technical correct, shall include all required test methods, and will require minimal editing.

100% satisfactory and timely completion

100% Inspection by COR

PRS#3. The contractor shall provide Revised Draft Test Protocol IAW Section

5.1.3.1 of

PWS.

Services provided within required timeline.

All BEP comments on the prior draft test protocol incorporated, as agreed between BEP and contractor.

100% satisfactory and timely completion

100% Inspection by COR

PRS#4. The contractor shall provide Final Test Protocol IAW Section

5.1.3.2 of

PWS.

Services provided within required timeline.

All DDOE comments on the prior draft test protocol incorporated, as agreed between BEP and contractor.

100% satisfactory and timely completion

100% Inspection by COR

PRS#5. The contractor shall conduct On-Site Compliance Testing IAW Section 5.1.4 of PWS.

Services provided within required timeline.

Sampling scheduled to minimize disruption to BEP production. All sampling completed in one multi-day sampling effort.

100% satisfactory and timely completion

100% Inspection by COR

PRS#6. The contractor shall provide Draft Sampling Report IAW Section 5.1.5 of PWS.

Services provided within required timeline.

Draft Sampling Report shall be technically correct, shall include information specific in this PWS, and shall require minimal editing.

100% satisfactory and timely completion

100% inspection by COR

PRS#7 The contractor shall provide Final Sampling Report IAW Section 5.1.5 of PWS

Services provided within required timeline.

All BEP comments on the prior draft sampling report incorporated, as agreed between BEP and contractor.

100% satisfactory and timely completion

100% inspection by COR