QUALITY ASSURANCE SURVEILLANCE PLAN.docx

593-27-1-577-0002 QUALITY ASSURANCE SURVEILLANCE PLAN (QASP)

Underground Fuel Storage Tank Cleaning, Fuel Testing, Fuel Polishing, and Fuel Replenishment

1. INTRODUCTION

This Quality Assurance Surveillance Plan (QASP) is pursuant to the requirements listed in the Performance Work Statement (PWS) entitled “Underground Fuel Storage Tank Cleaning, Fuel Testing, Fuel Polishing, and Fuel Replenishment.” This plan establishes the procedures and guidelines the VA Southern Nevada Healthcare System (VASNHS) Engineering Service and the designated Contracting Officer’s Representative (COR) will use to verify that the contractor achieves the required performance standards and service levels.

0. Purpose

0. The purpose of the QASP is to describe the systematic methods used to monitor performance and identify required documentation and resources to be employed. The QASP provides a means for evaluating whether the contractor is meeting the performance standards/quality levels identified in the PWS and the contractor’s quality control plan (QCP), and ensure the government pays only for the level of services received.

0. This QASP defines the roles and responsibilities of all members of the integrated project team (IPT), identifies the performance objectives, defines the methodologies used to monitor and evaluate the contractor’s performance, describes quality assurance documentation requirements, and describes the analysis of quality assurance monitoring results.

0. Performance Management Approach

1. The PWS structures the acquisition around required outcomes rather than prescribing every method the contractor must use. This QASP defines the performance management approach the VASNHS Engineering Service and COR will use to monitor the contractor’s work and determine whether the expected outcomes in the PWS are achieved. Performance data will be reviewed throughout the project so that safety, technical quality, schedule, documentation, environmental compliance, and restoration of the emergency fuel system can be evaluated objectively.

1. Performance management represents a significant shift from the more traditional quality assurance (QA) concepts in several ways. Performance management focuses on assessing whether outcomes are being achieved and to what extent. This approach migrates away from scrutiny of compliance with the processes and practices used to achieve the outcome. A performance-based approach enables the contractor to play a large role in how the work is performed, if the proposed processes are within the stated constraints. The only exceptions to process reviews are those required by law (federal, state, and local) and compelling business situations, such as safety and health. A “results” focus provides the contractor flexibility to continuously improve and innovate over the course of the contract if the critical outcomes expected are being achieved and/or the desired performance levels are being met.

0. Performance Management Strategy

2. The contractor is responsible for the quality of all work performed, including work performed by subcontractors. The contractor shall implement and maintain a Quality Control Plan (QCP) that addresses staffing, qualifications, permit-required confined-space entry, Lockout/Tagout (LOTO), fuel transfer, tank cleaning, fuel polishing, laboratory sampling, filter and strainer cleaning, waste disposal, diesel replenishment, restoration, documentation, timeliness, and correction of deficiencies. The contractor shall self-inspect its work and report performance and deficiencies to the COR. Government surveillance will verify results and will not relieve the contractor of its responsibility for complete and compliant performance.

2. The COR and other authorized Government representatives will monitor performance, inspect critical work, review contractor reports and laboratory results, and document whether the contractor is meeting the PWS requirements. The Government may require corrective action, re-performance, additional testing, or other contract remedies when the required standards are not achieved. No positive incentive or award fee is contemplated unless specifically established in the awarded contract.

1. ROLES AND RESPONSIBILITIES

1. The Contracting Officer (CO/KO) The Contracting Officer (CO/KO) is responsible for contract administration, interpretation of contract requirements, cost and schedule control, and resolution of contractual issues. The CO will designate a COR in writing to perform technical surveillance. Only the CO may modify the contract, authorize changes affecting price, scope, schedule, or terms, or provide contractual direction to the contractor.

1. The COR The COR is designated in writing by the CO to assist with technical administration and surveillance. The COR will coordinate access and scheduling, witness or inspect critical activities, review permits, qualifications, LOTO documentation, confined-space entry documentation, fuel test reports, delivery tickets, waste manifests, and closeout records, and document contractor performance using Attachment 2. The COR may stop work when an imminent safety, environmental, or operational hazard exists, but may not change the contract or direct work outside the awarded scope. Any matter affecting contract price, scope, terms, or schedule will be referred to the CO.

The Contractor Project Manager The Contractor Project Manager is responsible for overall execution, coordination, quality control, safety, environmental compliance, schedule management, and submission of required records. The Project Manager shall have authority to commit contractor resources, immediately correct unsafe or deficient conditions, and coordinate with the COR. The contractor remains responsible for all subcontractors, laboratories, fuel suppliers, transporters, and disposal facilities used in performing the contract.

1. IDENTIFICATION OF REQUIRED PERFORMANCE STANDARDS/QUALITY LEVELS

The required performance standards and acceptable quality levels are stated in the PWS and summarized in Attachment 1. Payment is contingent upon satisfactory completion and Government acceptance of the required services. Critical safety, environmental, fuel-quality, and emergency-system restoration requirements have an acceptable quality level of 100 percent. Failure to meet a required standard may result in stop-work direction, rejection, required re-performance, additional testing, corrective action, withholding of acceptance, reduction of payment for nonconforming services, adverse past-performance documentation, or other remedies available under the contract.

1. METHODOLOGIES TO MONITOR PERFORMANCE

0. Surveillance Techniques The Government will use surveillance methods appropriate to the risk and importance of each task. Primary surveillance methods include:

· 100 percent inspection or observation of critical safety activities, including LOTO, permit-required confined-space entry, atmospheric testing, tank isolation, fuel transfer setup, spill prevention, and final restoration.

· Document review of personnel qualifications, confined-space permits, rescue plans, LOTO records, laboratory chain-of-custody forms, fuel test reports, delivery tickets, waste disposal manifests, inspection checklists, photographs, and closeout reports.

· Periodic and milestone inspection of tank cleaning, fuel polishing, filter/strainer cleaning, fuel replenishment, operational testing, and final acceptance. Random observation and customer feedback may supplement these methods but will not replace required 100 percent surveillance of critical activities.

1. For each tank, the COR will verify that work is sequenced so the emergency fuel system retains the required operational capability. A tank shall not remain out of service overnight unless specifically authorized by the Government based on a validated operational need.

1. The COR will review pre-work submittals before hazardous work begins. Missing or unacceptable qualifications, permits, rescue provisions, LOTO procedures, or safety plans will result in work not being authorized to proceed.

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3. Customer Feedback The contractor is expected to establish and maintain professional communication between its employees and customers. The primary objective of this communication is customer satisfaction. Customer satisfaction is the most significant external indicator of the success and effectiveness of all services provided and can be measured through customer complaints.

Performance management drives the contractor to be customer focused through initially and internally addressing customer complaints and investigating the issues and/or problems, but the customer always has the option to communicate complaints to the CO or COR, as opposed to the contractor.

Customer complaints, to be considered valid, must set forth clearly and in writing the detailed nature of the complaint, must be signed, and must be forwarded to the COR. The COR will accept those customer complaints and investigate.

Customer feedback may also be obtained either from the results of formal customer satisfaction surveys or from random customer complaints.

3. Acceptable Quality Levels The acceptable quality levels (AQLs) in Attachment 1 are based on the risk and mission importance of the work. LOTO, confined-space entry, atmospheric monitoring, spill prevention, correct fuel product, tank fill limitations, environmental disposal, and restoration of the emergency fuel system require 100 percent compliance. Documentation and routine coordination generally require at least 95 percent timely and accurate performance, with 100 percent accuracy required for tank identity, fuel quantity, laboratory sample identification, and safety records.

1. QUALITY ASSURANCE DOCUMENTATION

4. 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 assessed using the performance monitoring techniques shown in Attachment 1.

1. Expected outcomes and surveillance requirements will be communicated during the pre-performance conference. The contractor will submit required plans and records, perform its own quality control, and promptly report deficiencies.

1. The COR will observe performance, review records, compare results with the PWS and Attachment 1, and document findings. Deficiencies will be communicated to the contractor and CO.

1. The contractor will correct deficiencies and provide evidence of correction. The COR will verify re-performance or corrective action before acceptance.

1. Trend information, repeated deficiencies, incidents, and schedule concerns will be elevated to the CO and considered during performance reviews and final contractor evaluation.

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4. Monitoring Forms Government quality assurance surveillance will be performed by the COR and any properly designated technical inspectors. Surveillance results will be recorded using Attachment 2 or equivalent Government monitoring records. Completed records will document whether required outcomes, service levels, safety requirements, and quality standards are being achieved.

1. The COR will retain completed surveillance forms, inspection notes, photographs, laboratory reports, permits, delivery records, waste manifests, deficiency notices, corrective action plans, and acceptance documentation in the official contract administration file in accordance with applicable records requirements.

1. ANALYSIS OF QUALITY ASSURANCE ASSESSMENT

5. Determining Performance

0. The Government will compare observed performance and required documentation against the standards and AQLs in Attachment 1. When a requirement is not met, the COR will document the deficiency and notify the CO. Depending on severity, the contractor may be required to stop work, correct the condition immediately, submit a corrective action plan, re-perform the work, repeat sampling or testing, replace nonconforming fuel or materials, or restore damaged equipment at no additional cost to the Government. Acceptance and payment may be withheld for incomplete or nonconforming work. Serious or repeated deficiencies may be reflected in contractor performance evaluations and may result in other remedies authorized by the contract.

5. Reporting

1. The COR will prepare surveillance reports at appropriate project milestones and at least monthly while work is ongoing. The report will summarize completed work, schedule status, safety and environmental performance, testing results, deficiencies, corrective actions, and acceptance status. The contractor’s progress reports, laboratory reports, disposal documentation, and completed monitoring forms will be included in the quality assurance file.

5. Reviews and Resolution

2. The COR may require the contractor’s Project Manager or designated alternate to meet with the CO, COR, Safety, Environmental Management, Energy Plant representatives, and other Government personnel as needed to discuss performance. Reviews may be held before mobilization, at project milestones, after any serious deficiency or incident, and at closeout. Review topics may include:

· Monthly performance assessment data and trend analysis

· 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

· Safety incidents, near misses, environmental releases, fuel-quality concerns, schedule risks, unresolved deficiencies, and issues arising from surveillance activities.

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2. The COR will coordinate with the contractor and CO to resolve marginal or unacceptable performance. Safety or environmental deficiencies requiring immediate action will be addressed before work resumes.

2. The COR and contractor may jointly identify practical corrective actions; however, changes to scope, price, schedule, metrics, or contractual requirements must be approved in writing by the CO. No informal agreement or field direction may modify the contract.

ATTACHMENT 1: PERFORMANCE REQUIREMENTS SUMMARY

Required Services (Tasks) Performance Standards Acceptable Quality Levels Methods of Surveillance Incentive (Positive and/or Negative) (Impact on Contractor Payments)

SERVICE or STANDARD: Select the applicable task from Attachment 1 (for example: LOTO, confined-space entry, tank cleaning, fuel polishing, laboratory testing, fuel replenishment, or final restoration).

SURVEY PERIOD: Identify the date, tank number(s), work shift, or project milestone reviewed.

SURVEILLANCE METHOD (check):

☐ Random Sampling ☒ 100% Inspection ☒ Periodic Inspection ☐ Customer Complaint LEVEL OF SURVEILLANCE (check):

☒ Each Critical Activity ☒ Each Tank/Milestone ☒ Monthly While Work Is Active ☒ As Needed PERCENTAGE OF ITEMS SAMPLED DURING SURVEY PERIOD: 100% for critical safety, fuel-quality, environmental, and restoration tasks; otherwise enter the actual percentage inspected.

ANALYSIS OF RESULTS: Compare observed performance and required documents against the applicable PWS standard and Attachment 1 AQL. Identify the tank/task inspected, records reviewed, deficiencies observed, corrective actions required, and whether re-inspection is necessary.

Observed Service Provider Performance Measurement Rate: _______% Service Provider’s Performance (check): ☐ Meets Standards ☐ Does Not Meet Standards Narrative of Performance During Survey Period: Document what was observed, whether the standard was achieved, any safety or environmental issues, laboratory or delivery results reviewed, deficiencies issued, contractor response, and final disposition.

07/21/2026 Dwight Bryan

PREPARED BY: ___________________________________ DATE: _________________

EXAMPLE 1 - CRITICAL SAFETY SURVEILLANCE

SERVICE OR STANDARD: LOTO and Permit-Required Confined-Space Entry - Tank No. ____

SURVEY PERIOD: ____________________

SURVEILLANCE METHOD: 100% Inspection / Direct Observation / Document Review LEVEL OF SURVEILLANCE: Each entry and each isolation

PERCENTAGE SAMPLED: 100%

ANALYSIS OF RESULTS: The COR reviewed the accepted entry permit, atmospheric meter calibration, pre-entry and continuous readings, entrant/attendant/entry-supervisor assignments, rescue provisions, ventilation, communications, PPE, and LOTO verification. Work may proceed only when all requirements are acceptable.

PERFORMANCE: ☐ Meets Standards ☐ Does Not Meet Standards NARRATIVE/COR COMMENTS: ________________________________________________________________

EXAMPLE 2 - TECHNICAL QUALITY SURVEILLANCE

SERVICE OR STANDARD: Tank Cleaning, Fuel Polishing, Sampling, and Laboratory Testing - Tank No. ____

SURVEY PERIOD: ____________________

SURVEILLANCE METHOD: 100% Milestone Inspection / Document Review LEVEL OF SURVEILLANCE: Each tank

PERCENTAGE SAMPLED: 100%

ANALYSIS OF RESULTS: Verify removal of sludge, sediment, and water; review before/after photographs; confirm fuel volume processed; review chain-of-custody records and laboratory results; confirm filters/strainers were cleaned or replaced; and document any required re-cleaning, re-polishing, or repeat testing.

PERFORMANCE: ☐ Meets Standards ☐ Does Not Meet Standards NARRATIVE/COR COMMENTS: ________________________________________________________________

EXAMPLE 3 - FUEL REPLENISHMENT AND RESTORATION

SERVICE OR STANDARD: Red-Dyed ULSD Delivery, Tank Fill Verification, and Return to Service - Tank No. ____

SURVEY PERIOD: ____________________

SURVEILLANCE METHOD: 100% Observation / Delivery Record Review / Functional Test LEVEL OF SURVEILLANCE: Each delivery and each tank restoration

PERCENTAGE SAMPLED: 100%

ANALYSIS OF RESULTS: Verify correct ASTM D975-compliant fuel, tank identity, authorized quantity, pre/post tank level, no overfill above the authorized level or 85% maximum, no spill, accurate delivery records, leak-free reassembly, correct sensor operation, and successful return to service.

PERFORMANCE: ☐ Meets Standards ☐ Does Not Meet Standards NARRATIVE/COR COMMENTS: ________________________________________________________________