Attachment C - Range Mining - New Contract QASP FINAL 04.26.23.pdf

Contract Number: TBD VA LETC Indoor Firing Ranges Clean-up & Hazardous Waste Removal

QUALITY ASSURANCE SURVEILLANCE PLAN

Project Title: VA LETC Indoor Firing Ranges Clean-up & Hazardous Waste Removal

Contract Description: The VA Law Enforcement Training Center (LETC) in North Little Rock, Arkansas requires a vendor to provide labor, material, insurance, licenses, and equipment required to clean and mine the shooting range including disposal of hazardous lead waste resulting from provisions of such services in an Environmental Protection Agency (EPA) approved landfill. There are two indoor shooting ranges. Two services per year are required with ranges being alternated for mining and cleaning during the period of performance. Two visits per range per year are required. Each range is required to have a complete rubber replacement once every three (3) years.

Contractor’s Name: TBD

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 accomplishes the work. Rather, the QASP is created with the premise that the contractor is responsible for management and quality control actions to meet the terms of the contract. 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 coordinate changes with the contractor. Copies of the original QASP and revisions shall be provided to the contractor 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: To be assigned

Organization or Agency: Department of Veterans Affairs, Law Enforcement Training Center

b. Contracting Officer’s Technical Representative (COR) – The COR is responsible for technical administration of the contract and shall assure proper Government surveillance of the contractor’s 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: Scott Roy ACOR Billy Cunningham

c. Other Key Government Personnel – TBD

3. CONTRACTOR REPRESENTATIVES

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

a. Program Manager –

b. Other Contractor Personnel –

Title:

4. PERFORMANCE STANDARDS

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

The Performance Requirements Summary Matrix, paragraph 2,3, in the Performance Work Statement (PWS), includes performance standards. The Government shall use these standards to determine contractor performance and shall compare contractor performance to the Acceptable Quality Level

(AQL).

Quality Assurance Surveillance Plan (QASP)

Performance Standards

Task Number Task Performance

Indicator Standard Acceptable

Quality Level

Method of Surveillance Score

3.1 Provide cleaning and mining of the shooting ranges.

100% Direct observation

3.1.1

Provide services to the VA LETC to be completed in September and May of the base period and each exercised option period.

100% Direct Observation / Inspection.

3.1.2

The contractor shall ensure that all applicable laws have been complied with concerning mining, packaging, labeling, and transporting.

Services shall comply with requirements under OSHA regulations

29 CFR 1910.1025

and CFR 1926.22.

100% 100% Inspection .

3.2.1

Recycle and Basic Clean LE7500 Bullet Trap- Range size 54’8” wide, 110’3” long, 15 shooting lanes.

100%

Direct Observation and 100% Inspection

Indicator Standard Acceptable

Quality Level

Method of Surveillance Score

3.2.1.1

After arriving on site, contractor employees will mobilize the work site with contractor equipment and supplies. The range ventilation system will be turned on before work commences to establish negative pressure in the range before disturbing lead dust. The contractor shall monitor negative pressure inside the range while working. The work site will be organized and then regulated with lead warning signs and lead danger tape to prevent unauthorized access to the work area. A decontamination unit or wash station will be set up before work activities that will disturb any lead dust. If there are any openings in the range, they will be sealed.

Contractor personnel shall wear personnel protective gear and respirators, contractor shall provide personnel protective gear as necessary.

100% 100%

Indicator Standard Acceptable

Quality Level

Method of Surveillance Score

3.2.1.2

Contractor shall perform air monitoring inside and outside the range- at elevations between 4-6 ft.

off of the ground, during the performance of this service.

Trained, on-site personnel will run OSHA personal air samples on each job classification employee. The contractor shall also run an inside and outside area sampled daily.

Final air clearances will be run on the last day of the job with a 24-hour turnaround time for results on air quality in the shooting range before re-occupancy. The samples will be run from 2-8 hours per day depending upon the daily activity.

All final air clearance samples will be less than the action level of 30 GH/m3 (micrograms per cubic meter of air) in an 8-hour TWA (time-weighted average) which is an employee’s average airborne exposure in any 8- hour work shift of a 40-hour work week which shall not be exceeded per OSHA

1910.1025 and 1926.62. The sampling methodology will be per American Industrial Hygiene Association (AIHA) recommendations using .8mm mixed cellulose sampling cassettes.

All samples will be closed-faced.

Sampling pump flow rates shall be between 3 and 10 liters/minute and each sample shall encompass a minimum of 200 liters. Sampling pumps shall be calibrated immediately before and after samples are drawn. The samples will be analyzed by an AIHA Accredited and OSHA-approved laboratory using NIOSH method 7082 (atomic absorption) for lead content. Upon receipt of laboratory lead in air totals, the contractor shall calculate the 8-hour time-weighted average for each sample and provide a written report of the finding to the LETC. The final report shall include original copies of laboratory-certified data results.

Sampling shall meet the OSHA

1910.1025 and 1926.62 requirements for shooter exposure monitoring of personnel for compliance purposes.

100% Direct Observation

Indicator Standard Acceptable

Quality Level

Method of Surveillance Score

3.2.1.3

The contractor shall remove approximately 135 cubic feet or 5 cubic yards of granular rubber and projectiles per lane concentrating on target zones.

The contractor will ensure that all rubber material has been removed from the bullet trap. The rubber material removed from the bullet trap will be recycled by special vacuums that will separate most of the spent lead projectiles from the rubber.

The granular rubber will then be put back into the bullet trap during the recycling and leveled to the proper slope.

100% Direct

/ Inspection.

Indicator Standard Acceptable

Quality Level

Method of Surveillance Score

3.2.1.4

For services that require complete rubber replacement, all rubber will be removed from the bullet trap and properly packaged for disposal. The bullet trap will be refilled with new, unused rubber and leveled to the proper slope. The bullet trap is estimated to hold 51,000 lbs of granulated rubber plus an additional 3,000 lbs during complete rubber replacement.

Rubber for the scheduled service shall be drop-shipped to the LETC before the service begins.

LETC does not have space to store the material and a lift gate will be required as LETC does not have a loading dock or a forklift to move the rubber material.

100% Direct

/ Inspection.

Indicator Standard Acceptable

Quality Level

Method of Surveillance Score

3.2.1.5

Wet method for lead dust control.

The contractor will use an airless sprayer with amended water to mist the air during the shoveling and recycling of the granular rubber.

This task shall be performed after the regulated work area is established.

During this task, lead exposure levels above the action level are expected and personal protective gear shall be worn.

100% Direct Observation

3.2.1.6

Shoveling Rubber.

The contractor shall remove the granular rubber and spent lead projectiles out of the bullet trap by hand using medium and small-size shovels. The material shall be placed slowly on the floor and never thrown from the bullet trap onto the floor.

Observation.

Indicator Standard Acceptable

Quality Level

Method of Surveillance Score

3.2.1.7

Recycling Granular Rubber.

The contractor shall set up recycle vacuums and use the vacuums to move the rubber from the floor back into the bullet trap.

During this process, the spent lead and tungsten projectiles will be separated from the rubber material and left on the ground.

100% Direct Observation.

3.2.1.8

Supply containers and package spent rubber for recycling.

100% Direct Observation.

3.2.1.9

Packaging aged rubber. During the process, the contractor using a shovel will pick up the aged rubber and pour it into plastic buckets or drums. The containers will be wet-wiped and staged in approved United Nation / Department Of Transportation

(UN/DOT)

containers for proper hazardous waste disposal by the contractor.

Indicator Standard Acceptable

Quality Level

Method of Surveillance Score

3.2.1.10

Cleaning Rubber from the Tungsten Shot. During this process, the contractor will use HEPA (High- Efficiency Particulate Air) vacuums to remove excess rubber from the projectiles before packaging them into buckets or drums for the metal recycler.

3.2.1.11

Supply containers and package the spent lead projectiles for recycling.

100% Direct Observation.

3.2.1.13

Packaging Spent Projectiles.

During the process, the contractor, using a shovel will pick up the spent lead and tungsten projectiles and pour them into plastic buckets or drums. The containers will be wet-wiped and staged for the metal recycler.

100% Direct Observation.

3.2.1.14

Visually inspect bullet trap components for wear/damage, compare manufacturer's specifications and inform the VA- LETC of any visual defects.

100% Inspection.

Indicator Standard Acceptable

Quality Level

Method of Surveillance Score

3.2.1.15

Bullet Trap Maintenance:

Inspect the bullet trap to ensure the rubber levels conform to the manufacturer’s specifications.

Also, inspect the bullet trap for any loose or missing nuts and bolts and are replaced or tightened them as necessary. Any deficiencies shall be brought to the attention of the

VA-LETC.

100% Inspection.

3.2.1.16

Replace and/or tighten any loose or missing nuts and bolts on the accessible exterior parts of the bullet trap.

100% Inspection.

3.2.1.18

Install 48 new gum rubber curtains (in total), (Applies to Range 1 located in Building 191 & Range 2 in Building 195).

This shall be done in conjunction with the complete rubber replacements.

100% Direct Observation/

3.2.1.19

Inspect the supply and safety bins for the proper level of granular rubber.

100% Direct

Indicator Standard Acceptable

Quality Level

Method of Surveillance Score

3.2.1.20

Fill the supply and safety bins with granular rubber from the bullet trap. If the bullet trap is deficient or rubber, the contractor will install new rubber, and provide additional rubber as needed.

(Approximately 3,000 lbs per range for recycling and releveling)

3.2.1.21

HEPA vacuum-accessible intake vents over the bullet traps.

100% Direct Observation

3.2.1.22

HEPA vacuum and wet wipe the accessible backside surfaces of the J-8 baffler (1st baffler over bullet trap)

100% Direct

3.2.1.23

Squeegee debris from the top of the gum rubber curtains

100% Direct

3.2.1.24

HEPA vacuum-accessible floor areas underneath the bullet trap

100% Direct

3.2.1.25

HEPA vacuum and wet wipe the accessible back side surfaces of the ceiling baffles.

3.2.1.26 HEPA vacuum and wet wipe target tracks

100% Direct

Indicator Standard Acceptable

Quality Level

Method of Surveillance Score

3.2.1.27

Wet-wipe shooters' booths and all horizontal and vertical surfaces from the firing line to the back wall and from the bottom of the safety ceiling to the floor.

100% Inspection

3.2.1.28

HEPA vacuum the shooting range floor and walls up to 10 feet.

100% Inspection

3.2.1.29

HEPA vacuum the first 220 sq. ft. of the floor outside the entrance to the shooting range.

100% Inspection

3.2.1.30

Properly package and label in

UN/DOT-

approved containers all cleaning supplies and personal protective equipment as lead-contaminated hazardous waste created by these services for proper disposal by the contractor.

100% Direct Observation

3.3.2

The waste will be disposed of in an EPA-approved landfill with the proper manifesting

100%

Direct Observation of paperwork (manifest).

Indicator Standard Acceptable

Quality Level

Method of Surveillance Score

3.3.4

Up to approximately fourteen (14) 55-gallon drums and two (2) Gaylord boxes, supplied by the contractor, of lead-contaminated hazardous waste are expected to be created from this service. Waste generated shall be picked up on the last day of service or no later than 24 hours after the service.

100% Direct Observation.

3.3.5

For periods of service requiring complete rubber replacement, approximately 51,000 pounds of rubber-contaminated hazardous waste is expected to be created from this service.

100% Direct Observation.

3.3 Waste Disposal 100%

Observation / with Manifest

Indicator Standard Acceptable

Quality Level

Method of Surveillance Score

3.6.2

Daily Status Report: The contractor shall submit Daily Status Reports to the COR detailing contractor performance in the execution of the tasks in this contract. This report will also serve as a baseline for guiding project execution as well as schedule performance.

100% Direct

/ Inspection

5. METHODS OF SURVEILLANCE

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

a. DIRECT OBSERVATION. (Can be performed periodically or through 100% surveillance.) Performance element 1, 4, 6. 100% of indicators described are reviewed and reported.

b. 100% INSPECTION. (Evaluates outcomes on a periodic basis. Inspections may be scheduled [Daily, Weekly, Monthly, Quarterly, or annually] or unscheduled, as required.)

(Evaluates all outcomes.) Performance element 2, 3, 4, 5: 100% of indicators described are reviewed by the COR and reported.

c. USER SURVEY. (Combines elements of validated user complaints and random sampling.

Random survey is conducted to solicit user satisfaction. May also generate inspections and sampling.

Reporting and Consumer Satisfaction

d. PERIODIC SAMPLING. (Variation of random sampling. However, sample is only taken when a problem/deficiency is suspected. Sample results are applicable only for the specific work inspected. Since sample is not entirely random, it cannot be applied to total activity performance.)

e. RANDOM SAMPLING. (Designed to evaluate performance by randomly selecting and inspecting a sample of cases.

f. Analysis of contractor's progress reports.

Outcomes

6. RATINGS

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

100% Positive Performance

95% Neutral Performance

90% Negative Performance

7. DOCUMENTING PERFORMANCE

a. ACCEPTABLE PERFORMANCE (100% RATING)

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

b. UNACCEPTABLE PERFORMANCE (90% RATING)

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. The CDR will specify if the contractor is required to prepare a corrective action plan to document how the contractor 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 review the contractor's corrective action plan to determine acceptability.

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

8. 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 yearly or more often as necessary to assess performance and shall provide a written assessment.

Signature – Contractor Program Manager

Signature – Contracting Officer’s Representative

Attachment 1

Contract Performance Report

1. Contract Number:

2. Prepared by: Scott Roy

3. Date and time of observation:

4. Observation:

Examples of items to include in a report are:

• Method of surveillance.

• How frequently you conducted surveillance.

• Surveillance results. • Number of observations.

5. Performance Rating (in accordance with QASP, paragraph 6):

Signature – Contracting Officer’s Representative Date

Attachment 2 Contract Discrepancy Report (CDR)

TO: (Contractor Program Manager or onsite representative)

FROM: Scott Roy

1. Contract Number:

2. Date and time observed discrepancy:

3. Discrepancy/Problem/Issue:

4. Corrective action plan:

5. A written corrective action plan is/is not required. [If a written corrective action plan is required include the following] The written Corrective Action Plan will be provided to the undersigned not later than <# days after receipt of this CDR.>

Signature – Contracting Officer’s Representative Date

Received by:

Signature – Contracting Program Manager or Onsite Representative Date

Distribution:

<Name & Title – Contracting Officer>

The COR may initiate a CDR at any time, including whenever the number of monthly recorded defects for a performance standard exceeds the allowable number of defects; anytime unacceptable performance is determined critical in nature and requires formal corrective action; and whenever an unfavorable trend is detected in contractor performance.