ATCH 1_PWS_Barriers_17May21.pdf

FA5613‐21‐Q‐0008

Attachment 1, Performance Work Statement

PERFORMANCE WORK STATEMENT (PWS)

FOR

PREVENTIVE MAINTENANCE,

SAFETY INSPECTIONS & REPAIR

OF

VEHICLE

CRASH-BEAM AND WEDGE BARRIERS,

TIRE KILLER, BOLLARDS, ARM BARRIERS,

QUICK FOLDING & SLIDING GATES

IN THE

KAISERSLAUTERN MILITARY COMMUNITY

(KMC)

19 April 2021 v.1

Table of Contents

SUBJECT Page Number

1.0. Description of Services

2.0. General Information

3.0. Services Summary

4.0. Government Furnished Property and Services

5.0. Appendices

Appendix A – Workload Estimates (in accordance with Appendix B)

Appendix B – Equipment List

1. DESCRIPTION OF SERVICES.

This is a non-personal services contract, the Government shall not exercise any supervision or control over the contract service providers performing the services herein. The contractor shall provide all non-personal services, management, tools, supplies, materials, equipment, parts, transportation and labor necessary to perform preventive maintenance (PM), safety inspections and repairs of vehicle crash-beam and wedge barriers, tire killer, bollards, arm barriers, quick folding and sliding gates in the Kaiserslautern Military Community (KMC), Ramstein Air Base, Ramstein Air Base- CTS, Kaiserslautern-Vogelweh, Kaiserslautern-Einsiedlerhof, Kaiserslautern-Kapaun Air Station. Every aspect of the service of each equipment (listed in Appendix B) shall be performed in accordance with (IAW) the standards set forth in this PWS to ensure continuous safe operation of installed active vehicle barriers (AVB) to meet Anti-Terrorism and Force Protection (AT/FP) standards in conjunction with (ICW) Unified Facilities Criteria UFC 4-022-01, dated 27 July 2017, and the Air Force Instruction, AFI 31-101 Integrated Defense (ID), both applicable for entry control facilities and access control points with installed active vehicle barriers such as final denial barriers (FDB).

1.1 TECHNICAL DESCRIPTION OF EQUIPMENT

Vehicle crash-beam and wedge barriers, tire killer, bollards, and some arm barriers are hydraulically operated. Sliding gates and some arm barriers are electrically operated. Barriers and gates consist of commercial and industrial types. The barriers and gates consist of but are not limited to structural framework with electrical system, electrical motor, hydraulic system, hydraulic lines/hoses, and a mechanical hydraulic system for manual operation, IAW Appendix B, Equipment List.

1.2. CONTRACTOR QUALIFICATIONS.

Services as requested herein shall be performed only by qualified personnel trained and certified for the service required. The contractor shall submit certificates of competency (Befähigte Person für kraftbetriebene Fenster, Tueren und Tore / competent person for power driven windows, doors and gates) of employees to the Contracting Office submitted with the proposals. The training certificates shall be obtained through an accreditation authority (for example TÜV – Technischer Überwachungsverein, DEKRA). Contractor technicians shall have knowledge of the current German safety and accident prevention regulations (Deutsche Gesetzliche Unfallversicherung – DGUV) and the usage of guidelines and generally recognized rules of engineering IAW commercial practices to be able to assess the condition of the equipment properly. The contractor shall be familiar with the different equipment used under this contract. Technical rules must be in compliance with Technische Regeln fuer Arbeitsstaetten (ASR A1.7) based on Berufsgenossenschaftliche Regeln (BGR) 232 “Richtlinien für kraftbetriebene Fenster, Türen und Tore” (English translation: Trade Association Rules 232 “Guidelines for power driven windows, doors, and gates”) of Deutsche Gesetzliche Unfallversicherung (DGUV). The contractor shall be familiar with the different equipment used under this in the scope of this contract as listed in IAW Appendix B, equipment list. The contractor shall provide and maintain throughout the life of this contract current certifications with Perimeter Protection Group (PPG) to ensure their ability to obtain certified and warranted parts, to ensure the integrity of our security systems.

1.3. MAINTENANCE SERVICES.

The contractor shall perform maintenance including but not limited to cleaning (removal of all old lubricant, grease, dust, natural debris etc.) surrounding and inside, on all installed equipment itself listed in Appendix B IAW manufacturer recommendations/specifications/instructions or the regulations and standards listed in this PWS to ensure reliable and continuous safe operation. Whatever is more stringent shall apply. After each maintenance, a clearly legible, visible and waterproof adhesive sticker must be affixed to each equipment dedicating safety inspection was done and when next safety inspection is due. Maintenance and safety inspections shall include, but are not limited to fuses, main unit/switches, frame/structural integrity, hydraulic main unit and control block, hydraulic cylinders, lines/pipes, oil pressure, greasing of lube points, detection sensors of various kinds, electronic components and the overall general condition IAW manufacturer recommendations and specifications. The maintenance shall be accomplished by the last day of the month as requested. Deviations from scheduled timeframe have to be coordinated and approved by the Contracting Officer’s Representative (COR). For apparent findings the contractor shall submit a repair quote together with his maintenance report IAW Paragraph 1.5., 1.5.1., 1.5.2. and 1.11 and Appendix B Current Equipment List. As units are replaced, upgraded, decommissioned, lose warranty the equipment list will be updated at least annually. For the scope of this contract any changes upward or downward of 20% from contract inception is considered in-scope and will not require a modification.

1.3.1. PREVENTIVE MAINTENANCE SHALL BE PERFORMED AS:

Annual maintenance in the month of September for sliding gates.

Semi-annual maintenance in the months of October and April for vehicle crash-beam barriers, bollards and arm barriers identified as AVB (Active Vehicle Barriers) as listed in IAW Appendix B, equipment list.

Quarterly maintenance in the month of October, January, May and July for quick folding gates.

Quarterly maintenance in the months of October, January, May and July for Vehicle Crush-Beam Barriers, Wedge Barriers and Tire Killer identified as FDB (Final Denial Barriers) as listed in IAW Appendix B, equipment list.

1.3.2. MAINTANCE REPORT

The contractor shall submit a written maintenance report for each Equipment to the COR within eight (8) business days after completion the maintenance of each item. The report shall include, but is not limited to:

(a) Date and time of the service

(b) Location, equipment/serial number and type

(c) Full operational test

(d) Overall condition including discrepancies cited and repairs needed

(e) Amount of time spent on inspection

(f) Name of the technician performing the service

1.3.3 INITIAL INSPECTION SERVICES

Upon inception of this contract, the contractor along with the COR shall do an initial inspection of all equipment within 60 days of contract award. Any equipment upon the initial inspection that is deemed to be in a non-working condition upon receipt of this contract shall be documented and sent to the Contracting Officer and COR. This report shall describe any visual problems seen as well as a description of how the equipment is non-functional. Contractor shall not be responsible to return the equipment to working order, maintain, or inspect until the government has taken the action to repair or replace the items. Once the government has repaired or replaced the equipment written notice will be provided to the contractor with the updated Appendix B, Equipment List and from that point on the contractor shall be required to maintain, inspect, and repair IAW the terms and conditions of this PWS. This will not impact the scope consideration as mentioned in paragraph 1.3 of this PWS.

1.4. SAFETY INSPECTION.

The Contractor shall carry out annual safety inspections on all equipment listed in Appendix B of this PWS. Special requirements (DGUV-V3 / electrical safety checks) occurs every four years and applies for electrical components testing. Load testing on electrical components must be carried out in the base year and fourth option year of this contract.

All safety inspections shall be in compliance with, but not limited to the applicable regulations and guidance listed in paragraph 1.11 of this PWS.

1.5. REPAIR SERVICE.

All repair work shall be carried out IAW paragraph 1.11. and standard commercial practices using parts specified by the respective equipment manufacturers. Downtime of equipment shall be kept to an absolute minimum. The contractor shall notify the COR in writing (email is acceptable) about the status of the repair as soon as possible, but no later than the following business day. Upon non-availability of OEM (Original Equipment Manufacturer) parts, items of equal or higher quality are permissible upon COR’s concurrence. The contractor shall provide written documentation (for example, a letter/email from the parts manufacturer) to the COR explaining any delays in the delivery of parts to meet delivery timelines IAW Paragraph 1.11. The contractor shall complete the repair within one

(1) business day or as scheduled with the COR after receiving the required parts from the manufacturer. Travel time will not be reimbursed separately.

1.5.1 ROUTINE REPAIR SERVICE CALLS

The COR will notify the contractor of the required repairs and will generate a Work Task referencing call number.

The required work must be completed with this call number. The contractor shall report to the equipment identified within two (2) hours after verbal/written notification by the COR. The contractor shall survey the repair and provide the COR a required parts list and an estimated completion of repair, within one (1) business day of survey. Upon parts availability, the contractor shall commence repair work within one (1) business day and inform the COR in advance about the planned time and date of the scheduled service.

1.5.2. EMERGENCY REPAIR SERVICE CALLS

The contractor shall report to the equipment identified to be repaired within two (2) hours after verbal/written notification by the COR. The contractor shall survey the failure and provide an on-the-spot repair, if possible. In case of non-availability of replacement parts, another call will be placed for the next business day to initiate the repair. All other procedures remain as described in paragraph 1.5.1.

1.5.3. ROUTINE AND EMERGENCY REPAIR REPORTS.

The contractor shall provide separate repair reports for each equipment served to the COR within eight (8) business days after completion of work. The reports shall include:

(a) Date, time and call number of the service

(b) Location, equipment/serial number and type

(c) Full functionality test

(d) Service performed (malfunction and description of work) and parts used

(e) Amount of time worked

(f) Name of the technician performing the service

1.6. REQUIRED DOCUMENTATION.

All required Documents, Reports and Schedules IAW paragraph 1.9. shall be sent electronically (Adobe PDF) per email to the COR.

1.7. SCHEDULES.

The contractor shall coordinate/schedule the dates and times services will be rendered with the respective Facility Manager (FM) and submit a written maintenance schedule to the COR no later than fourteen (14) business days prior to the start date of the maintenance and safety inspections. The schedule shall include the estimated dates, times, building numbers and locations. Any schedule changes shall be coordinated in writing with the contractor, FM and the COR at least eight (8) business days prior to the originally scheduled dates. The COR will provide an Installation Facility Manager point of contact list.

1.7.1. DEVIATIONS TO SCHEDULE.

In the event the scheduled service has to be re-scheduled for any of the equipment listed in Appendix B, the contractor and Facility Manager (FM)/alternate must agree to the day change and notify the COR in writing. The contractor shall submit to the COR deviations ASAP but not later than the day before service is scheduled.

1.8. MONTHLY REPAIR STATUS

The contractor shall submit a monthly report listing with open calls in writing to the COR but no later than the first business day of the following month.

1.9. DELIVERABLES.

Deliverables (Report, Document, etc.) PWS paragraph

Due Date (business days)

Initial Equipment inspection Report 1.3.3 Submitted within 75 days after contract award.

Maintenance and Safety Schedule 1.6., 1.7., 1.7.1. Within fourteen (14) business days prior to the start date of the maintenance and safety inspections

Written Maintenance and Safety Inspection Reports 1.3., 1.3.1., 1.3.2., 1.4., 1.6.

Within eight (8) business days after completion of work

Provide parts list for needed repair 1.5., 1.5.1., 1.5.2., 1.6., 1.11.

Submitted NLT than one (1) business day from repair survey

Provide Repair Status 1.5., 1.5.1.

1.5.2., 1.11.

Not later than one (1) business day receiving initial repair call

Monthly Repair Status 1.8. Not later than the first business day of the following month

Routine and Emergency Repair Reports 1.5., 1.5.1., 1.5.2., 1.6.

Within eight (8) business days after completion of work

Quality Control Plan 1.6., 2.0. Submitted NLT the pre-performance conference

1.10 . WASTE DISPOSAL.

All trash and hazardous waste, generated as a result of services performed, routine or emergency repairs, shall be disposed of-base, IAW the German National Waste Disposal Act (Abfallbeseitigungsgesetz – AbfG) and at no additional cost to the Government.

1.11. APPLICABLE GUIDANCE.

The Contractor shall comply with all applicable regulations and requirements. The below list may not be complete and all-inclusive. Systems shall be checked IAW:

GENERAL INFORMATION

Manufacturer Specifications DGUV Deutsche Unfallverhütungs Vorschriften (UVV) / German Accident Prevention Regulations Technische Regeln für Arbeitsstätten / Technical Rules for Workplaces “ASR A1.7”

Berufsgenossenschaftliche Regeln (BGR) 232 (Richtlinien für kraftbetriebene Fenster, Türen und Tore / Trade Association Rules 232 “Guidelines for power driven windows, doors, and gates

DGUV 209-070 (Sicherheit bei der Hydraulik bei der Instandhaltung / Safety in Hydraulic Maintenance) DGUC Regel 113-020 “BGR 237” (Hydraulic-Schlauchleitungen / Hydraulic Hose Lines) DGUV Regel 100-500 “BGR 500” (Betreiben von Hebebühnen / Operation of Hydraulic Lifts) Betriebssicherheitsverordnung (BetrSichVO) / Ordinance on Industrial Safety and Health DGUV-V3 Prüfung elektrischer Betriebsmittel / Testing of electrical Systems DIN EN VDE 0100 (Daten und Fakten für das Errichten von Niederspannungen / Low-voltage Electrical

Installations) EU-Maschinenrichtlinie 2006/42/EG / EU Directive 2006/42/EC on Machinery WHG (Wasserhaushaltsgesetz – German Water Act)

2. QUALITY CONTROL

The contractor shall have and maintain a written quality control plan to ensure services are performed IAW this PWS. The contractor shall have procedures to identify and prevent defective services from recurring. As a minimum, the contractor shall have quality control procedures that address the areas identified in paragraph 3, Services Summary.

2.1. QUALITY ASSURANCE.

The government will surveille, inspect and document the contractor’s performance to ensure services rendered are IAW the performance thresholds set in this PWS and technical compliance to applicable regulations and specific manufacturer guidance are met. To record validation results the COR will use the contractor’s work schedule or modified version thereof to conduct inspections and the routine and emergency repair reports to ensure all terms of regulations and manufacturer instructions are met to ensure safe and endurable operation of installed equipment subject to this contract is given. Results of the validation then become the official Air Force record of the contractor’s performance. When a performance threshold has not been met or contractor performance has not been accomplished as required, the COR will initiate and provide the CO with a Corrective Action Report (CAR) for issuance to the contractor. The contractor shall respond to the CAR IAW the instructions provided and return it to the CO within five (5) calendar days of receipt. The CO will forward the contractor’s response to the COR once received. The COR will perform re-inspection within one (1) business day of receipt of contractor’s response.

2.2. UNACCEPTABLE PERFORMANCE.

The contractor shall report to the site location within two (2) hours after notification to correct unacceptable performance. The contractor shall re-perform at no cost to the Government. Any re-performance and/or unacceptable performance will be documented by the COR and may result in the Government seeking equitable price reduction or adequate consideration IAW FAR52.212-4, Contract Terms and Conditions – Commercial Items.

2.3. CONTRACT MANAGER.

The Contractor shall provide the name of a contract manager (primary and alternate) who shall be responsible for the performance of work and have full authority to act on behalf of the contractor on all contract matters relating to the daily operations of this contract. The contract manager shall be available during normal duty hours (0700-1600). The Contractor shall be able to meet with the COR to resolve any contract issues. The contract manager and alternate shall be able to understand, read, speak, and write basic and technical English (to speak English with sufficient structural accuracy and vocabulary to participate in formal and informal conversations on practical, social, and professional topics). The contractor shall provide to the CO and COR, five (5) business days after award, a list with the names and contact information’s including their individual function for all personal performing under the scope of this contract.

Any required changes to this list shall be submitted in writing to the CO and COR, ten (10) business days prior to the change taking effect.

2.4. HOURS OF OPERATION.

The contractor shall coordinate all work to be accomplished IAW this PWS with the COR and Facility Manager (FM/alternate for each service to be maintained and repaired. Emergency repairs may be required during non-business or off-hours (early AM or late PM), Monday through Sunday including holidays. Business hours are 0700-1600, Monday through Friday. The time for maintenance and repairs to be performed shall be coordinated before any work is scheduled.

Contractor’s hours of operations shall be IAW table below.

Hours of Operation

Maintenance Services and

Safety Inspection

Repairs

Emergency

Repairs

Monday-Friday and US Federal Holidays

0700-1600 0700-1600 1600-0700

Saturdays, Sundays, & German and US Federal Holidays

24 hours

US/German Federal Holidays.

1st January 3rd Monday in January

rd. Monday in February

New Year’s Day Martin Luther King Day Washington’s Birthday

Neujahr (US) and (German)

(US)

(US)

** Good Friday Karfreitag (German) ** Easter Monday Ostermontag (German) 1st May Labor Day Tag der Arbeit (German) ** Ascension Day Christi Himmelfahrt (German) ** Whit Monday Pfingstmontag (German) Last Monday in May Memorial Day (US) ** Corpus Christi Day Fronleichnam (German) 4th July

1st Monday in September Independence Day Labor Day

(US)

(US)

3rd October 2nd Monday in October

Day of German Unity Columbus Day

Tag der Deutschen Einheit (German)

(US)

1st November All Saints’ Day Allerheiligen (German) 11th November 4th Thursday in November

Veteran’s Day Thanksgiving

(US)

(US)

25th December Christmas Weihnachten (US) and (German) 26th December 2nd Day of Christmas 2. Weihnachtstag (German)

When a US Federal Holiday is on a Saturday, the preceding Friday will be observed. When the holiday is on a Sunday, the following Monday will be observed.

** Indicates dates change each year – Moveable Holidays

2.5. PERFORMANCE OF SERVICES DURING MILITARY EXERCISES OR OPERATIONS.

Work stoppages may occur during the execution of this contract due to military exercises or operations. During these times, access to areas supporting the exercise or operation may be curtailed or denied. During scheduled and unscheduled exercises or operations, the contractor must be prepared to postpone performance in coordination with the COR until immediately after completion of the military exercise or operation. No additional cost will be incurred to the Government for the waiting time until the exercise or operation is over.

2.6. SECURITY REQUIREMENTS.

The contractor personnel shall comply with all requirements and procedures IAW AFFARS 5352.242-9000, Contractor Access to Air Force Installations.

2.6.1 CONTRACTOR/EMPLOYEE BASE PASS AND IDENTIFICATION, SPECIAL CLEARANCES

AND VEHICLE PASSES.

Contractor personnel shall obtain an Installation Common Access Card (ICAC) not later than fourteen (14) days prior to the Period of Performance (PoP). In order to obtain the ICAC, the Contractor is required to submit to the COR following;

USAFE IMT 79 (Request for ICAC) Memo of ICAC request Copy of Passport Security Questionnaire for simple security check Police Good Conduct Certificate (Polizeiliches Fuehrungszeugnis)

USAFE IMT 79, Memo of ICAC request, and the Security Questionnaire will be provided by the COR, 786

CES/CEOES.

Contractor personnel shall present completed documentation to Security Forces personnel at bldg. #134, Ramstein Air Base, to obtain their ICAC. Contractor personnel can only gain access to the KMC after the security check has been passed with a positive result. It is the responsibility of the contractor to collect and return the ICAC or personnel that is no longer employed within one (1) week, in case contract is terminated and/or after end of the PoP.

2.6.2 ACCESS TO RESTRICTED AREAS.

Access to secure areas must be coordinated with the COR. Restricted areas require notification through the COR to the FM/alternate at least one (1) week prior to the date of service is scheduled to allow ample time for coordination.

2.6.3. ESCORT.

For any restricted/secure area access in conjunction with (ICW) the scope of service, the COR will arrange for an escort and entry authorization at the designated place of performance.

2.7. SPECIAL QUALIFICATIONS.

Contractor employees performing services shall be able to speak English sufficiently well to communicate on a basic level with on-site personnel.

2.8. CONFORMANCE WITH ENVIRONMENTAL MANAGEMENT SYSTEMS.

The contractor shall perform work under this contract consistent with the relevant environmental policy and objectives identified in the installation environmental management system (EMS) applicable for your contract. The contractor shall perform work in a manner that conserves water, energy, and other resources to the maximum extent feasible and ensure minimum production of waste as possible, giving preference to recycling and reutilization opportunities.

Furthermore, the contractor shall give preference to less toxic materials whenever available and still reliable for their work. In the event an environmental nonconformance or noncompliance of host nation and USAF environmental laws and regulations associated with the contracted services is identified, the contractor shall take corrective and/or preventative actions. In the case of a noncompliance, the contractor shall respond and take corrective action immediately. In the case of a nonconformance, the contractor shall respond and take corrective action based on the time schedule established by the EMS Coordinator. In addition, the contractor shall ensure that their employees are aware of the environmental management system on base and how these requirements affect their work performed under this contract. All on-site contractor personnel shall receive the installation EMS awareness level information.

2.8.1. CONFORMANCE WITH ENVIRONMENTAL REQUIREMENTS.

The contractor shall perform all work in accordance with applicable German and US Air Force environmental laws, regulations and operating standards, including but not limited to, the Final Governing Standards (FGS) for Germany.

The contractor shall be immediately capable of understanding and addressing environmental laws and regulations as they pertain to work performed under this contract. The FGS for Germany and other important environmental laws and requirements applicable to all contractors working on base will be made available upon request.

2.9. DOD MISSION ESSENTIAL SERVICES DURING CRISIS.

IAW DODI 1100.22, Policy and Procedure for Determining Work Force Mix, paragraph 5b, it is determined that none of the services as stated in this PWS are mission essential.

3. SERVICES SUMMARY (SS).

The SS provides information on contract requirements and the expected level of the contractor’s performance. The contract service requirements are summarized in performance objectives. The performance threshold briefly describes the acceptable levels of service required for each requirement. These thresholds are critical to mission success. During the first 30 days of the contract, two (2) errors for each performance objective will be allowed in an effort to overcome normal phase-in problems (this applies when there is a change of contractor only).

Performance Objective PWS Paragraph(s)

Performance Threshold

Remedy

SS-1. Perform Maintenance:

All equipment is properly maintained IAW the PWS.

1.3., 1.3.1., 1.3.2., 1.6., 1.7., 1.7.1., 1.9.

No more than 1 deficiency per quarter

Re-performance within 2 hours of notification

SS-2. Perform Safety Inspections:

Safety inspections are properly performed on all equipment by the date specified in the written schedule.

1.4., 1.6., 1.7., 1.7.1., 1.9.

No deficiencies Re-performance within 2 hours of notification

SS-3. Perform Routine Repair:

Responses and repairs are made within the specified time.

1.5., 1.5.1., 1.5.3., 1.6., 1.9., 1.11.

No deficiencies Re-performance within 2 hours of notification

SS-4. Perform Emergency Repair:

Responses and repairs are made within the specified time.

1.5., 1.5.2., 1.5.3., 1.6., 1.9., 1.11.

No deficiencies Re-performance within 2 hours of notification

SS-5. Provided Submittals, Schedules and Reports:

Maintenance and Safety Schedule Written Maintenance and Safety

Inspection Reports Cost Estimate for Routine and

Emergency Repairs Provide Repair Status Monthly Repair Status Routine and Emergency Repair

Reports provided are complete, accurate and delivered within time specified.

1.2., 1.3., 1.3.2., 1.4., 1.5., 1.5.1., 1.5.2., 1.5.3., 1.6., 1.7., 1.8., 1.9., 1.11.

No more than 3 late, incomplete or inaccurate submittals/schedules/ reports per performance year

Re-performance within Close of Business (COB) next day after notification

SS-6. Provide Quality Control Plan

2.1., 2.1.1. Submitted NLT the pre-performance conference

N/A

4. NON GOVERNMENT FURNISHED PROPERTY AND SERVICES WILL BE PROVIDED.

4.1. DAMAGE TO GOVERNMENT PROPERTY. The contractor shall report all damages to U.S. Government property within one (1) hour after occurrence to the COR.

5. APPENDIX.

A. Workload Estimate Data per Year B. Equipment List (Separate excel document)

Appendix A

Workload Estimate Data per Year

ITEM

DESCRIPTION OF SERVICE

ESTIMATED

QUANTITY

1 Annual Maintenance with safety inspections on Sliding Gates (IAW Current Equipment List)

76 ea

2 Semi-Annual Maintenance with safety inspections on

AVB

(IAW Current Equipment List)

222 ea

3 Quarterly Maintenance with safety inspections on Quick Folding Gates (IAW Current Equipment List)

28 ea

4 Quarterly Maintenance with safety inspections on

FDB

(IAW Current Equipment List)

88 ea

5 Repair Service Calls

(based on a 5 year average)

144 ea

6 Emergency Repair Service Calls

(based on a 5 year average)

34 ea

*This workload estimate does not bind the government to these fixed quantities. A workload estimate is just an estimate of the best guess based on the current equipment list and historical data and its purpose is to provide the contractor data needed to access probable workload and perform risk assessment needed to formulate a fair and reasonable FFP.