QASP HazardousWasteServices.pdf

QUALITY ASSURANCE SURVEILLANCE PLAN

For: HAZARDOUS WASTE TRANSPORTATION, TREATMENT, and DISPOSAL SERVICES

Contract Description: The services in this Contract are to provide all labor, equipment, and materials necessary for transportation, treatment, and disposal of hazardous waste generated by USACE activities at civil works projects and USACE owned facilities located within the Portland District.

Contents

1 INTRODUCTION

1.1 Purpose

1.2 Performance Management Strategy

2 ROLES AND RESPONSIBILITIES

2.1 The Contracting Officer (KO)

2.2 Contract Specialist

2.3 The Contracting Officer’s Representative (COR)

2.4 Quality Assurance Evaluator (QAE)

3 IDENTIFICATION OF REQUIRED PERFORMANCE STANDARDS/QUALITY

LEVELS

4 METHODOLOGIES TO MONITOR PERFORMANCE

4.1 Surveillance Techniques

4.2 Customer Feedback

4.3 Acceptable Quality Levels (AQLs)

5 QUALITY ASSURANCE DOCUMENTATION

5.1 The Performance Management Feedback Loop

5.2 Monitoring Forms

6 ANALYSIS OF QUALITY ASSURANCE ASSESSMENT

6.1 Determining Performance

6.2 Reporting

6.3 Reviews and Resolution

ATTACHMENT 1: PERFORMANCE REQUIREMENTS SUMMARY

ATTACHMENT 2: QUALITY ASSURANCE MONITORING FORM

ATTACHMENT 3: QUALITY ASSURANCE MONITORING CHECKLIST

1 INTRODUCTION

This Quality Assurance Surveillance Plan (QASP) is established in accordance with the requirements outlined in the Performance Work Statement (PWS) entitled "Hazardous Waste

Transportation, Treatment and Disposal Services." This plan details the procedures and guidelines the U.S. Army Corps of Engineers (USACE), Portland District, will use to monitor the contractor's performance and ensure that the required performance standards and service levels are met.

1.1 Purpose

This QASP outlines a systematic approach for the Government to evaluate the contractor's performance under this contract. Specifically, this QASP addresses:

• The aspects of the contractor's performance that will be monitored.

• The methods by which monitoring will be conducted.

• The personnel responsible for conducting the monitoring activities.

• The procedures for documenting monitoring efforts and findings.

This QASP is designed to assess what outcomes the contractor achieves, not how the contractor performs the work. The contractor retains full responsibility for managing its operations and implementing a robust quality control system to meet all contract requirements. The

Government's role is to provide objective, fair, and consistent performance evaluations. The

QASP also acknowledges that unforeseen and uncontrollable events may impact performance.

This QASP is a dynamic document that the Government may periodically review and revise to ensure its continued validity, utility, and enforceability. The Government will coordinate any changes with the contractor. The contractor and designated Government personnel involved in surveillance activities will receive copies of the original QASP and all subsequent revisions.

The development of this QASP is aligned with the Federal Acquisition Regulation (FAR), specifically Subpart 37.6 (Performance-Based Acquisition) and 46.4 (Government Contract

Quality Assurance). Furthermore, FAR Subpart 46.103 (Contracting Officer Responsibilities) mandates the creation of quality assurance surveillance plans for service acquisitions."

1.2 Performance Management Strategy

The contractor's Quality Control (QC) program is the mechanism by which they measure and maintain that quality. QC applies to all work performed under the contract, regardless of whether the work is performed by contractor employees or subcontractors.

The contractor’s QCP will detail the staffing and procedures for self-inspecting quality, timeliness, responsiveness, customer satisfaction, and other performance requirements outlined in the PWS. The contractor will develop and implement a performance management system with processes to assess and report its performance to the designated government representative. This

QASP is designed to leverage the contractor’s QC program.

The government representative(s) will monitor performance and review performance reports submitted by the contractor to determine how the contractor is performing against the communicated performance objectives. The government will make determinations regarding incentives based on performance measurement metric data and notify the contractor of those decisions. The contractor will be responsible for making necessary changes in processes and practices to ensure performance is effectively managed.

2 ROLES AND RESPONSIBILITIES

2.1 The Contracting Officer (KO)

The Contracting Officer (KO) is responsible for:

• Monitoring contract compliance.

• Contract administration.

• Cost control.

• Resolving any differences between the observations documented by the Contracting

Officer’s Representative (COR), Quality Assurance Evaluator (QAE), and the contractor.

• Designating one full-time COR as the government authority for performance management.

• Identifying and designating additional representatives serving as technical inspectors, based on the complexity of the services and the contractor’s performance.

Assigned KO: Darrell Hutchens

Telephone: (971) 270-8351

Email: Darrell.D.Hutchens@usace.army.mil

2.2 Contract Specialist

The Contract Specialist is responsible for:

• Acting as the acquisition consultant and serves as the liaison between the contractor and the KO.

Important Note: The Contract Specialist is not authorized to make any contractual commitments or to authorize any contractual changes on the government’s behalf. Any changes that the contractor believes may affect the contract price, terms, or conditions must be referred to the KO for action. Government surveillance may occur under the inspection of services clause for any service relating to the contract.

Assigned Contract Specialist: Joshua Mahon

Telephone: (503) 808-5014

Email: Joshua.D.Mahon@usace.army.mil

2.3 The Contracting Officer’s Representative (COR)

The Contracting Officer’s Representative (COR) is designated in writing by the CO to act as their authorized representative in assisting with contract administration. The COR’s limitations are defined in the written appointment letter.

The COR is responsible for:

• Technical administration of the project.

• Ensuring proper government surveillance of the contractor’s performance.

• Completing QA monitoring forms used to document the inspection and evaluation of the contractor’s work performance.

• Notifying the KO of unacceptable performance.

Important Note: The COR is not authorized to make any contractual commitments or to authorize any contractual changes on the government’s behalf. Any changes that the contractor believes may affect the contract price, terms, or conditions must be referred to the KO for action.

Government surveillance may occur under the inspection of services clause for any service relating to the contract.

Assigned COR: Carson Freels

Telephone: (503) 808-4323

Email: Carson.T.Freels@usace.army.mil

2.4 Quality Assurance Evaluator (QAE)

The QAE(s) are the Project POC(s) who observes Contractor performance while on Project.

The QAE(s) are responsible for:

• Notifying the COR of unacceptable performance.

Important Note: The QAE(s) is not authorized to make any contractual commitments or to authorize any contractual changes on the government’s behalf. Any changes that the contractor believes may affect the contract price, terms, or conditions must be referred to the KO for action.

Government surveillance may occur under the inspection of services clause for any service relating to the contract.

3 IDENTIFICATION OF REQUIRED PERFORMANCE

STANDARDS/QUALITY LEVELS

The specific performance standards and quality levels required under this contract are detailed in the PWS and in Attachment 1, "Performance Requirements Summary."

A rating scale shall be used to determine a positive, neutral, or negative outcome. The following ratings shall be used:

EXCEPTIONAL:

Performance significantly exceeds contract requirements to the Government’s benefit.

SATISFACTORY: Performance meets contractual requirements.

UNSATISFACTORY: Performance does not meet contractual requirements.

4 METHODOLOGIES TO MONITOR PERFORMANCE

4.1 Surveillance Techniques

To minimize the performance management burden, the government will use simplified surveillance methods to evaluate contractor performance, when appropriate. The primary surveillance methods include:

• Random Monitoring: The COR and/or QAE will conduct unscheduled monitoring of contractor activities.

• 100% Inspection: Each month or per task order, the COR and/or QAE will oversee on-site contractor activities and compare them against the Performance Requirements

Summary (Attachment 1). The Quality Assurance Monitoring Form (Attachment 2) will be completed to document the inspection.

• Periodic Inspection: The COR and/or QAE will perform annual inspections using the

Quality Assurance Checklist and Monitoring Forms (Attachments 2 & 3). The District

Environmental Compliance Coordinator (ECC) will also conduct an annual inspection of on-site contractor activities, as well as an inspection of the contractor’s facilities.

• Customer Complaint: Periodic inspections may also be conducted by the COR and/or

QAE because of complaints received from project personnel.

4.2 Customer Feedback

The contractor is expected to establish and maintain professional communication with its customers. The primary goal of this communication is to ensure customer satisfaction. Customer satisfaction is a significant indicator of the success and effectiveness of the services provided and can be measured through customer feedback and, especially, customer complaints.

While performance management encourages the contractor to be customer-focused by proactively addressing customer complaints, customers always have the option to communicate complaints directly to the COR, rather than going through the contractor.

To be considered valid, customer complaints must:

• Be submitted in writing.

• Clearly detail the nature of the complaint.

• Be signed by the complainant.

• Be forwarded to the COR and/or QAE.

The COR and/or QAE will investigate valid customer complaints using the Quality Assurance

Monitoring Form (Attachment 2). Customer feedback may also be obtained through formal customer satisfaction surveys or unsolicited customer comments.

4.3 Acceptable Quality Levels (AQLs)

The AQLs included in Attachment 1, Performance Requirements Summary Table, are structured to allow the contractor flexibility in managing how the work is performed, while providing negative incentives for performance shortfalls. For critical activities, such as those involving the handling of hazardous waste, the desired performance level is generally established at 100 percent.

Example: Attachment 1 might specify that 99.9% of all waste manifests must be error-free. Any error rate above 0.1% would trigger a penalty, as defined in the contract.

5 QUALITY ASSURANCE DOCUMENTATION

5.1 The Performance Management Feedback Loop

The performance management feedback loop begins with the communication of expected outcomes. Performance standards are expressed in the PWS and are assessed using the performance monitoring techniques outlined in Section 4 and detailed in Attachment 1.

5.2 Monitoring Forms

The government’s QA surveillance, conducted by the COR and/or QAE, will be documented using the monitoring forms provided in Attachments 2 and 3. These forms, when completed, will document the government’s assessment of the contractor’s performance under the contract to ensure that the required results of hazardous waste transportation, treatment, and disposal are being achieved.

The COR will retain a copy of all completed QA surveillance forms.

6 ANALYSIS OF QUALITY ASSURANCE ASSESSMENT

6.1 Determining Performance

The government will use the monitoring methods described in Section 4 to determine whether the performance standards, service levels, and AQLs have been met. If the contractor fails to meet the minimum requirements, the government may take the following actions:

• Corrective Action Plan: Require the contractor to develop a corrective action plan that details how and by what date they intend to bring performance up to the required levels.

• Price Reduction: When defects in services cannot be corrected by re-performance, reduce the contract price to reflect the reduced value of the services performed.

• Government Performance: If the contractor fails to promptly re-perform the services or take the necessary action to ensure future performance conforms to contract requirements, the government may, by contract or otherwise, perform the services and charge the contractor any cost incurred by the government that is directly related to the performance of such service.

• Cure Notice: Issue a Cure Notice, giving the contractor a specified period to correct the deficiencies.

• Termination: Terminate the agreement for Government convenience or for Cause.

Waste Characterization Penalties:

• If the contractor fails to submit waste characterization results to the COR and the Project

POC within 15 calendar days of the sampling date, USACE will penalize the contractor.

This penalty is designed to offset costs incurred by USACE because of the contractor’s non-compliance.

The following monetary penalties will be assessed if the contractor fails to submit waste characterization results to the COR and the Project POC within 15 calendar days:

Days Late Penalty to Contractor

Within 15 days None

1-3 days $25.00

4-7 days $50.00

8+ days $100.00

6.2 Reporting

At the end of each quarter, the QAE will prepare a written report for the COR summarizing the overall results of the quality assurance surveillance of the contractor’s performance. This written report, which includes the contractor’s submitted monthly report and the completed quality assurance monitoring forms (Attachment 2), will become part of the QA documentation. It will enable the government to demonstrate whether the contractor is meeting the stated objectives and/or performance standards, including cost/technical/scheduling objectives.

6.3 Reviews and Resolution

The COR may require the contractor’s project manager, or a designated alternate, to meet with the COR and other government personnel as deemed necessary to discuss performance evaluation. The COR will define a frequency of in-depth reviews with the contractor, including appropriate self-assessments by the contractor; however, if the need arises, the contractor will meet with the COR as often as required or per the contractor’s request.

The agenda of these reviews may include:

• Issues and concerns of both parties.

• Projected outlook for upcoming months and progress against expected trends, including a corrective action plan analysis.

• Recommendations for improved efficiency and/or effectiveness.

• Issues arising from the performance monitoring processes.

The COR must coordinate and communicate with the contractor to resolve issues and concerns regarding marginal or unacceptable performance. The COR and contractor should jointly formulate tactical and long-term courses of action. Decisions regarding changes to metrics, thresholds, or service levels should be clearly documented. Changes to service levels, procedures, and metrics will be incorporated as a contract modification at the convenience of the

KO.

ATTACHMENT 1: PERFORMANCE REQUIREMENTS SUMMARY

PERFORMANCE REQUIREMENTS SUMMARY

Performance Objective Performance

Standard

Acceptable

Quality Levels

Surveillance

Validated

Complaints

Transportation for

Chemical Characterization

Samples

5.6.1 0 deficiencies permitted

100% Inspection 1 per quarter

Waste Characterization

Laboratory and Profiling

Services 5.6.2

0 deficiencies permitted

Periodic

Inspection

0 deficiencies permitted

Transportation for Treatment and Disposal 5.6.3

0 deficiencies permitted

100% Inspection 1 per quarter

Drum Replacement and/or

Over-packing

5.6.4 0 deficiencies permitted

100% Inspection 1 per quarter

Waste Treatment and

Disposal 5.6.5

0 deficiencies permitted

Periodic

Inspection

0 deficiencies permitted

Annual Waste

Management Reports

5.6.6 0 deficiencies permitted

100% Inspection 0 deficiencies permitted

ATTACHMENT 2: QUALITY ASSURANCE MONITORING FORM

SERVICE or STANDARD:

SURVEY PERIOD:

SURVEILLANCE METHOD (Check):

Random Monitoring 100% Inspection Periodic Inspection Customer Complaint

LEVEL OF SURVEILLANCE (Check):

Monthly Annually As needed

PERCENTAGE OF ITEMS SAMPLED DURING SURVEY PERIOD: ______ %

ANALYSIS OF RESULTS:

Observed Service Provider Performance Measurement Rate: ______%

Service Provider’s Performance (Check): Meets Standards

Does Not Meet Standards

Narrative of Performance During Survey Period:

PREPARED BY: ___________________________________ DATE: _________________

ATTACHMENT 3: QUALITY ASSURANCE MONITORING

CHECKLIST

1 Quality of Work Yes/No Date Comments

1.1 Facilities

Utilize a RCRA Part A/B facility

Use oil treatment/recycling facility

Preapproved waste treatment facility

NELAC or A2LA Certified Lab

1.2 Equipment

Own & Operate Vehicles

Spill Response Kits

Bill of Lading/Manifest

Spill Containment (10%)

Emergency Response Guide Book

Communication System

1.3 Quality Control

Quality Control Process

2 Timely Performance Yes/No Date Comments

2.1 Schedule

Visit Coordinated with POC

Work Completed per Timetable

3 Effectiveness of Management Yes/No Date Comments

3.1 Emergency Response

Spill Response Contractor

Injury or Accident Procedures

Notification Procedures

3.2 Insurance

Business Automobile Liability

Commercial General Liability

Pollution Liability

3.3 Regulatory

Unresolved Notices of Noncompliance

Notices of Violation

Enforcement Actions

3.4 Personnel

Environmental Manager

2 HAZWOPER Trained Personnel

Use of Contractor Manpower Reporting Tool

4 Compliance with Safety Standards Yes/No Date Comments

4.1 Plans

General Health and Safety Plan

Safety and Health Program (RCRA)

Hazard Communication Plan

DOT Security Plan

4.2 Training

40 Hour HAZWOPER

DOT Hazmat Employee

CPR & First Aid

First Responder

Hazard Communication

Pre-Work Safety Briefing

Safe Work Practices

Proper Selection & Use of PPE

4.3 Personnel

Last Physical

Medical Professional Review

ID Badges