Corporate Safety Manual

Procedure 11-1

QUALITY ASSURANCE PROGRAM

SECTION 1 - PURPOSE

To describe the quality assurance activities exercised by NORTHSTAR during the estimating,
engineering, procurement, and abatement phases of all major lead and asbestos abatement
projects.

SECTION 2 - SCOPE

This Quality Assurance Program establishes the Quality Assurance requirements for
NORTHSTAR and any subcontractors performing work for NORTHSTAR. The Quality
Assurance Program identifies and describes the integral elements of the Quality Assurance
activities that apply to the broad spectrum of work performed by NORTHSTAR and its
subcontractors for all activities associated with a specified project.

SECTION 3 - POLICY

NORTHSTAR is committed to the safe execution of its projects, within each of the applicable
regulations, guidelines and its Corporate Safety Manual. An integral part of successfully
pursuing this policy is to ensure that the required level of quality in all site activities is achieved,
while also taking the necessary measures to ensure the health and safety of the site personnel and
the public, and safeguarding the environment.

The success of the project depends on the required level of quality being achieved in every
functional area including:

 design and analysis  construction

 procurement  decontamination

 fabrication  decommissioning

 installation  training

 surveying  documentation

NorthStar Group Services, Inc. QUALITY ASSURANCE PROGRAM

Corporate Safety Manual Procedure 11-1
Revised: 05/01/14 Page 1 of 8
Corporate Safety Manual
Procedure 11-1

NORTHSTAR recognizes a responsibility to assure its clients that it is dedicated to insuring

dependable, reliable, and quality service in all work performed within applicable codes, legal
requirements, and construction standards as defined in NORTHSTAR contracts.

SECTION 4 - GENERAL

The entire NORTHSTAR Corporate Safety Manual is in complete accordance with this
program; however, practices for individual projects may vary as established by the contractual
requirements, providing such requirements are not in conflict with applicable codes and
standards.

In use, the NORTHSTAR Safety Manual is our quality assurance program and is reviewed on a
continuing basis for changes that can simplify or improve the effectiveness of the program.
Suggestions will be carefully evaluated by safety and other appropriate departments before final
action.

4.1 Applicable

The objective of this quality assurance program is to ensure that NORTHSTAR projects
are conducted with safe and reliable workmanship to establish confidence that systems
and work practices are designed and implemented in accordance with established and
applicable codes, standards, and contract specifications.

This quality assurance program is applicable to:

 Quality assurance activities related to estimating, engineering, procurement,

and maintenance of equipment for which NORTHSTAR has responsibility;

 Quality assurance activities related to work practices for which

NORTHSTAR has construction responsibility; and

 Those job site quality assurance activities conducted by another contractor

currently under contract to NORTHSTAR as a subcontractor.

SECTION 5 - OPERATIONAL RESPONSIBILITY

Although the key individuals, who are involved in implementing this quality assurance program,
are an integral part of the functional construction organization, this will not be allowed to
subordinate or compromise their quality assurance responsibilities. The respective
responsibilities of these individuals are as follows:

NorthStar Group Services, Inc. QUALITY ASSURANCE PROGRAM

Corporate Safety Manual Procedure 11-1
Revised: 05/01/14 Page 2 of 8
Corporate Safety Manual
Procedure 11-1

5.1 Company President

The company president has the ultimate responsibility for the implementation of this
quality assurance program. The company president's responsibilities are accomplished
through:

 the preparation and signing of the quality assurance program policy statement
which establishes a governing company policy to conduct estimating,
engineering and work practices within this quality assurance program;
 delegation of the day-to-day administration of this quality assurance program
to individual project management; and
 an annual management review of this quality assurance program to determine
the status, adequacy, and effectiveness of the program.

5.2 Purchasing Manager

The purchasing manager is responsible for procurement of engineering and work practice
materials for NORTHSTAR projects. He or she confirms that major procurements are
processed in accordance with this quality assurance program. These duties and
responsibilities include:

 reviewing procurement documents;

 reviewing supplier quality assurance programs and procedures and performing
pre-award surveys of prospective suppliers; and
 reviewing drawings and specifications for proper quality requirements and
participating in design review of client design bases.

5.3 Project Superintendent

Each individual project superintendent is responsible for the management and direction
of his or her project, and for assuring that all activities on that project are conducted in
accordance with this NORTHSTAR quality assurance program. Duties and
responsibilities include:

 preparing detailed quality assurance and quality control procedures for all phases
of the project;

NorthStar Group Services, Inc. QUALITY ASSURANCE PROGRAM

Corporate Safety Manual Procedure 11-1
Revised: 05/01/14 Page 3 of 8
Corporate Safety Manual
Procedure 11-1

 assisting in the training of personnel in the requirements of the quality assurance

program;
 participating in audits of internal quality assurance activities;
 performing follow-up audits of corrective action commitments to correct previous
findings;
 assisting in evaluation of the quality assurance program effectiveness; and
 maintaining a working knowledge of the latest applicable codes and standards
utilized by NORTHSTAR in the completion of this project.

5.4 Supervisory Personnel

All supervisory personnel are responsible for the execution of all construction activities
and for coordinating this work with the project superintendent. These responsibilities
include, but are not limited to, the following:

 establishing and maintaining this quality assurance program which describes

NORTHSTAR's quality assurance activities;
 day-to-day administration of the quality assurance program;
 assuring that any other operating procedures or work practices, prepared by other
company departments, to supplement or support this quality assurance program is
consistent;
 stopping work when a condition adverse to quality warrants such action to
maintain a required quality level; and
 insuring that participating personnel are adequately trained in the requirements of
this quality assurance program and in the special skills required to perform their
job duties.

5.5 Site Safety Personnel

 performing daily inspections of the projects activities and work practices and
advising appropriate management of deviations from established policies and
procedures;
 conducting planned, periodic in-depth audits of the projects quality assurance
program to insure implementation of the program and to determine the
Company's ability to constantly operate within its parameters; and

NorthStar Group Services, Inc. QUALITY ASSURANCE PROGRAM

Corporate Safety Manual Procedure 11-1
Revised: 05/01/14 Page 4 of 8
Corporate Safety Manual
Procedure 11-1

 insure the results of all inspections and audits, performed in accordance with
these procedures, are documented and reviewed.

SECTION 6 - ADMINISTRATIVE RESPONSIBILITY

The preparation, review, approval, maintenance, issuance, revisions, additions, deletions and
recall of this quality assurance program will be the responsibility of the Director of Health and
Safety and Regulatory.

SECTION 7 - INSPECTIONS AND AUDITS

NORTHSTAR will continuously monitor the project to assure that requirements defined by the
scope of work and other documents presented in the contract package are being met.
NORTHSTAR will have adequate monitoring systems in place so that defects are discovered on
a timely basis to eliminate need for large amounts of rework to meet the contract requirements.

In addition, ascertain the following by daily inspections and periodic audits:

 determine if adequate measures have been established to prevent the inadvertent use of
nonconforming activities or work practices;
 insure that those nonconforming activities and work practices which may have been
identified have been appropriately corrected; and
 that adequate records are maintained of all activities affecting the quality assurance
program.

7.1 Communications

Direct, informal, and timely communications between NORTHSTAR's inspectors and the
client's inspectors will be considered mandatory, especially for notification points and in
the event of a problem development. NORTHSTAR will advise the client, in as
expeditious a manner as possible, of all situations where changes or compromises in
specifications are considered or where non-conformance is being encountered.

SECTION 8 - DESIGN CONTROL REVIEW

A design control, quality assurance and safety review shall be held when a new or modified
operation is to be started, a new process is developed or an existing process has been expanded
or significantly revised, a major item of capital equipment is to be purchased or put into service,

NorthStar Group Services, Inc. QUALITY ASSURANCE PROGRAM

Corporate Safety Manual Procedure 11-1
Revised: 05/01/14 Page 5 of 8
Corporate Safety Manual
Procedure 11-1

an unusual or hazardous construction activity is to be started, a chemical or hazardous substance

is to be handled or disposed of for the first time and the chemical or hazardous substance's
properties are significantly different from materials usually handled.

This review shall be held before the start up of the operation and after installation or revision is
sufficiently completed for a proper evaluation and/or physical inspection.

There must be adequate time provided following the evaluation and/or inspection and before
start up for the reviewing personnel to address any quality assurance and/or safety concerns that
may be developed.

8.1 Review Team Selection

A review team will normally be composed of safety personnel, project management, and
if warranted, members from disciplines of engineering, technical products, operations,
etc., depending on the requirements of the project. Other individuals from specialized
functions, both within and outside of NORTHSTAR, may be appointed to a team as
deemed advisable. The senior management member of the team will act as the team
leader. Additional members of a team may be composed of a representative from the
original project, operational personnel, and at least one or more members not directly
related to the project under review.

SECTION 9 - CALIBRATION REVIEW

The measuring of air pollutants or contaminants and the testing of equipment, products or
materials must be performed with the measuring and/or test equipment calibrated for each
specific operation as required by codes, standards and contract specifications. The project
superintendent will be responsible for the following:

 reviewing calibration records daily and monthly and establishing a list of equipment to
be calibrated;
 removing any equipment from use on the project for sufficient time to have adequate
calibration performed;
 if scheduled calibration of measuring and/or test equipment is found to be discrepant, or
the item found to be out of calibration, immediately notifying the appropriate vendor or
subcontractor; and

NorthStar Group Services, Inc. QUALITY ASSURANCE PROGRAM

Corporate Safety Manual Procedure 11-1
Revised: 05/01/14 Page 6 of 8
Corporate Safety Manual
Procedure 11-1

 Insuring that measuring and/or test equipment which is constantly found to be out of
calibration is either repaired or replaced.

9.1 Calibration Equipment

Tools, gauges, instruments, and other measuring and testing devices which, due to their
design, may inherently be or may become inaccurate must be calibrated using certified
equipment or standards traceable to the National Bureau of Standards when such
standards exist. When no national standards exist, calibration will be performed in
accordance with the instrument manufacturer's recommendations.

SECTION 10 - PROCUREMENT CONTROL

NORTHSTAR has established measures to assure that quality provisions are identified in
purchasing / subcontract documents for materials, equipment, and services. To the extent
necessary, purchases documents require subcontractors to provide quality assurance/quality
control consistent with the requirements to be satisfied by NORTHSTAR's quality assurance
program.

SECTION 11 - LEVEL OF QUALITY

The level of quality assigned to any project determines the degree of quality assurance/quality
control effort applied to verify conformance to the design and contract requirements. The
detailed assignment of a level of quality is based on the contract requirements and job
complexity. The following establishes the quality assurance program activities imposed on
projects classified as level 1, level 2, 3 or level 4:

 Quality Level 1 - is defined as applying to those projects which requires a contractor

who has a documented Quality Assurance Program which meets the requirements of
ANSI/ASME NQA-1 “Quality Assurance Program Requirements for Nuclear Facilities.”
 Quality Level 2 - is defined as applying to those projects which requires a contractor that
has a documented Quality Assurance Program that adequately address the quality
requirements applying to work normally performed.
 Quality Level 3 - is defined as applying to those projects in which the contractor does
not need to have a documented Quality Assurance Program, but must have successfully
performed construction activities with the client in the past.

NorthStar Group Services, Inc. QUALITY ASSURANCE PROGRAM

Corporate Safety Manual Procedure 11-1
Revised: 05/01/14 Page 7 of 8
Corporate Safety Manual
Procedure 11-1

 Quality Level 4 – is defined as applying to those projects in which the contractor does
not need to have a documented Quality Assurance program and has not previously
performed any construction work for the client.

11.1 Levels of Inspection

Level 1 - In addition to letting project management prepare specifications, field

requisition materials, inspect upon job site arrival, and inspect at end of field activities,
include a pre-mobilization meeting, review required documentation on a daily basis,
make regular inspection as needed, and increased level of final testing. Also make daily
inspections, continuous testing and/or monitoring of critical activities, and continuous
monitoring of work in progress.

Levels 2 and 3 - In addition to letting project management prepare specifications, field

requisition materials, inspect upon job site arrival, and inspect at end of field activities,
include a pre-mobilization meeting, review required documentation on a daily basis,
make regular inspection as needed and increased level of final testing.

Level 4 - Let project management prepare specifications, let the field requisition
materials, do not require source inspection, inspect upon job site arrival, and inspect at
end of field activities.

SECTION 12 - TRAINING

Training of personnel performing activities affecting quality will be conducted to assure an

understanding of the quality assurance program and project requirements.

NorthStar Group Services, Inc. QUALITY ASSURANCE PROGRAM

Corporate Safety Manual Procedure 11-1
Revised: 05/01/14 Page 8 of 8