Attachment 06 - Quality Assurance and Surveillance Plan (QASP).pdf
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- Attached to
- Sasebo HW Disposal Federal contract opportunity
- Solicitation number
- SP450020R0008
- Issued by
- Defense Logistics Agency
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SP4500-19-R-0000
Sasebo HW
Source Selection Information See FAR 2.101 and 3.104
ATTACHMENT 06
QASP
Quality Assurance Surveillance Plan (QASP)
DLA Disposition Services Performance-Based Hazardous Waste Disposal Contract –
SP4500-19-R-0000
DLA Disposition Services Office Sasebo
The purpose of this document is to provide guidance on administering subject contract such that the best possible quality in performance can be assured through appropriate surveillance, and addressing of any performance failures as appropriate. The APL itself states the surveillance methods and reductions for failures. However, certain additional explanation and detail is provided herein as necessary:
I. Compliant Removal
1. “Days” in the timeframe column usually means calendar days unless the contract uses business days. Removal time for waste is 21 calendar days.
2. Accuracy shall be evaluated during a 12-month time period. “Accurate” as in “95% accurate” shipping documentation, means the percent of orders with accurate shipping documentation during the 12-month time period. If any significant error occurs in the shipping documentation of an order, the entire order is considered inaccurate for evaluation purposes.
3. The following should normally be considered significant errors:
a. Any errors in quantity of wastes being shipped (regulated or non-regulated).
b. Any errors impacting destination/location of wastes (i.e. wrong facility identified).
c. Typographical errors that don’t affect identification, quantity, or waste destination/location are normally not considered significant in and of themselves, however if they cumulatively require undue Government effort to rectify under a given order, they are considered significant.
4. “CSRs” are the DLA Disposition Services Form 1729 Collection Summary Reports completed by the Contracting Officer Representative (COR) for each location listed on the task order removed under the contract. They will be reviewed primarily to determine compliance with the removal phase of the total service being provided. CORs must annotate any deficiencies in Blocks 1 through 16 with an explanation as appropriate in the Remarks section on Page 2 of the form. Other methods of surveillance in the removal phase include such means as emails and other feedback from the COR and/or generators to determine contract compliance.
5. Compliant Removal is further divided into three phases – Pre-removal, Removal and
Post Removal. Pre-removal includes submittal of any applicable shipping documents (draft and final) and notifications. Removal is safe compliant marking and labeling of shipping containers and loading vehicles. Post-removal is compliant transportation to interim storage or final disposal facilities.
a. Pre-removal APLs are 95% accurate and 95% timely. Reductions for failed APLs can vary from 10 – 75% for Submittal of Shipping Documents, and 10-60% for Notifications, depending on the frequency and/or severity of the failure. The annual performance assessment (CPARS) may also be annotated.
b. Removal APL is 100% timely and 100% compliant because of the possible risk to personnel and ground, air and water if hazardous waste is spilled, and potential Notices of Violation of storage capacity or timeframes and resultant fines that the federal and state regulatory agencies could levy on our military customers.
Reductions for failed APLs range from 10 – 100%. CPARS reports will be documented.
c. Post-removal APLs are 100% timely and compliant. Reductions range from 10 – 100%, depending on the frequency and/or severity of the failure.
II. Compliant Disposal/Recycling
1. Use of the term “days” is the same as explained above.
2. The primary method of surveillance for evaluating compliance with required timeframes is the Overage Report. This report is distributed on a monthly basis for review/action, and indicates which line items are overdue under the contract. For evaluation purposes, 225 calendar days will be the cut-off for determining disposal for all items except wastes being incinerated, which have a disposal timeframe of 315 calendar days. Subsequent time for actual contractor input of Phase II tracking entries into BOSS shall not exceed 30 calendar days beyond these timeframes.
3. DLA Disposition Services Form 1878 will be used to determine accuracy of documents and inputs by the contractor for disposal in the tracking of Government waste and contract compliance.
4. For task orders, accuracy is based on the number of line items, e.g. if a task order contains 10 line items and 1 line item is improperly disposed of, or evidences a different disposal input error, that equals 90% accuracy. The Government reserves the right to determine whether these deficiencies are major or minor non-conformances, as follows:
a. High-Risk Category (Major Nonconformance):
National/Domestic Security-type Items: Items for which “demilitarization via service contract” is allowed or preferred and Certificates of Destruction (CDs) may be contractually required; i.e. Chemical Defense Equipment (CDE), Submarine Tiles, poisonous gases, reactive, oxidizers, DEA Watch list Items, etc., which could be used as weapons of terror.
Increased Regulatory Scrutiny-type Items: Items for which the customer is required by regulation to do any or all of the following:
- receive a Certificate of Destruction (CD)
- provide the final disposal method on their annual report
- pay annual waste fees, based on final management methods
b. Low-risk Category (Minor Nonconformance): Any item that is not in the high risk category will be considered a low risk; however, if minor deficiencies are repetitive such that significant Government resources are required to correct them, then the deficiencies can be considered a Major Nonconformance (High-Risk).
5. Acceptable performance levels for compliant disposal/recycling are 100% timely and compliant for regulated hazardous wastes, Demil required items, and compressed gas cylinders.
For nonhazardous waste the acceptable level is 95%. Reductions for failed performance range from 10 – 100%, depending on the severity or frequency. Performance will be documented on CPARs.
III. Compliant Special Services
1. Use of the terms “days” and “accurate” is the same as explained above.
2. The primary method of surveillance is CSRs as explained above, as well as the other feedback sources indicated on the APL Matrix.
3. Acceptable performance is 95% timely and 95% compliant and accurate. Reductions range from 10 – 100% for delivery of containers (roll-offs) and tank cleaning; and 10 – 75% for other special services, depending on the severity. Performance will be documented on CPARs.
For example, failure to deliver containers or clean tanks timely could result in a work stoppage.
IV. Reduction for Failed APL
1. As indicated in the APL matrix, the reduction for failure to meet APLs is the same in all performance areas. The 10-100% consideration available is broad to give the contracting officer full latitude considering all the possible performance shortcomings and the essentially unlimited variety of mitigating facts and circumstances.
2. If valid failure to meet an APL is identified prior to payment and consideration is warranted considering the pertinent facts, consideration is taken against that particular task order.
If the failure is identified after payment and consideration is warranted, it may be taken against an open task order on the same contract. The preference is return consideration to the affected generator(s).
3. In addition to the consideration and past performance annotation remedies available to the Contracting Officer under the APL Matrix, the Government may use such measures as partial or full terminations under FAR 52.249-2 and FAR 52.249-8, not exercising options, and ending a contract early without these measures as long as it is IDIQ and has met its minimum Government obligation for the period and a plan for a timely replacement contract is secured.
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