Signed_JOTFOC_Trinity_Pole_Repairs_Final_Redacted.pdf

WBR 1406.303-1 Form 1 TBD (May 2018)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

PR No: TBD Solicitation No.: 140R2019R0005 Project Name: Trinity Unit 1 Repair Rotor Poles In accordance with FAR 6.302, the proposed contractual action is pursuant to the statutory authority of 6.302-2 Unusual and compelling urgency

(1) Agency and Contracting Activity. Bureau of Reclamation, Mid Pacific Region, MP- 3800 Acquisition Services Group

(2) Nature/Description of Action. Negotiate a Firm Fixed Price contract with Voith Hydro, Inc. (Voith) for the urgent repair of all rotor poles at Trinity power plant, Unit 1.

(3) Description of Supplies/Services. The government need is the removal and reinstallation of 36 generator rotor poles. Voith will provide labor, tools and materials, transportation, and shop work to disassemble 36 poles to replace damaged laminations and to ensure proper fit of the amortisseur bars. The requirement is on a critical path where the work needs to be completed and the 36 poles returned to the Trinity Power Plant no later than March 2019. This date is needed to provide time to re-assemble the unit in time for the return to service date of April 15th when the Trinity River Restoration Program Record of Decision (ROD) flows commence.

Trinity Power Plant Unit 1 was indirectly damaged by the recent Carr Fire when smoke and fire retardant contacted live 230 kV transmission lines. This incident and other fire-related events caused bulk-electric system problems that damaged the unit’s damper bars, rotor pole laminations, and pole shoes.

The Commissioner for the Bureau of Reclamation recently started a Central Valley Project (CVP) Power Initiative that identifies opportunities to increase the value of the CVP power resource to CVP water and power customers. The CVP Initiative is directly related to efforts in reducing foregone power generation by reducing water spills.

Because of the Central Valley Improvement Act (CVPIA), the Trinity Flow Evaluation Studies, and the Trinity Environmental Impact Report/Environmental Impact Statement (EIR/EIS) Record of Decision, high Trinity River water releases are scheduled every April-May-June timeframe. The high flows exceed the capacity of the two Trinity generators. The remainder of the high flow releases are made through the hollow jet flow valves. If Trinity U1 is not in service due to ongoing repairs approximately $1.5 million of foregone power generation would result just for the month of May. In “wetter” years, higher flows are released to the Trinity River resulting in even greater amounts of foregone power generation.

When Trinity Power Plant is islanded due to extraordinary circumstances such as what existed during the Carr Fire, it becomes the sole power supply to the 14,000 residents of Trinity County. It is critical to restore this capability prior to the next fire season. In 2018, the fire season began on May 14 in Northern California. Otherwise, Trinity County could be exposed to prolonged power outages during another fire emergency.

Therefore, it is essential that efforts to quickly obtain electrical/mechanical parts and services to repair Trinity Unit 1 and have it operationally ready to complete commissioning/testing by April 15, 2019. This will ensure Unit 1 is ready to be returned to service and return to service to avoid power generation bypass water spilling at Trinity powerplant.

The estimated value is

(4) Statutory Authority Permitting Other than Full and Open Competition.

(5) Demonstration of Contractor’s Unique Qualifications.

There are other firms with the capability to perform this work. However, Voith Hydro, Inc. (Voith) is the only contractor capable of performing the required work within the required timeframe for the following reasons.

Authority FAR Coverage Application 41 U.S.C. 253(c)(1) FAR 6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements 41 U.S.C. 253(c)(2) FAR 6.302-2 Unusual and compelling urgency

41 U.S.C. 253(c)(3) FAR 6.302-3 Industrial mobilization; engineering, developmental or research capability; or expert services

41 U.S.C. 253(c)(4) FAR 6.302-4 International Agreement 41 U.S.C. 253(c)(5) FAR 6.302-5 Authorized or required by statute 41 U.S.C. 253(c)(6) FAR 6.302-6 National Security 41 U.S.C. 253(c)(7) FAR 6.302-7 Public Interest 41 U.S.C. 3304(a)(1) FAR 6.302-1(c) Application for brand-name descriptions

FAR 13.501(a) Sole source (including brand name) acquisitions

• Voith has all the required preliminary safety and product data submittals completed and approved from an FY 2016 contract, R16PC0006 – Trinity Powerplant Generator Rewind. This contract included repair of 16 rotor poles in Unit 2. They will be able to mobilize and start work almost immediately after receiving Notice to Proceed. Voith is the only known contractor that has performed this work or similar work at this location within the last 5 years.

• To meet the urgent needs of the government, the contractor must have prior knowledge and experience with this vintage of generator pole type and design, originally manufactured by General Electric. Voith is known worldwide as an expert in hydroelectric power generation and their performance on the previous contract demonstrated they have the unique experience and knowledge that very few companies have.

• Voith, having recently completed rewinding both units at Trinity in addition to performing similar work to repair damaged rotor poles for Unit 2 is uniquely qualified to perform this limited scope type of repair work for Unit 1. Voith Hydro, Inc., has relevant knowledge of this type of damage, repair methods, use of specialized tooling, and an understanding of the material requirements to successfully make the necessary repairs. The repairs of the Unit 2 rotor poles last year are identical to the repairs for Unit 1 rotor poles needed now.

• Voith has demonstrated that they have a dedicated and unique relationship with suppliers in the industry. This was clearly demonstrated during performance of the FY16 Contract when they had to complete the same type of work in a very short outage period. Suppliers, transporters and Voith worked 7 days a week to meet the strict deadline.

• If another contractor had to come up to speed, the delay to start work may be up to 2 months for submittal preparation and acceptance. The SOW will allow Voith to simply resubmit previous submittals that have already been accepted as site specific plans on the FY16 project.

(6) Description of efforts made to maximize competition.

This will be a single source procurement due to the urgency of the repair needs. This requirement could not have been foreseen due to the natural fire disaster itself. Once the extent of damage was discovered, the urgent need for repairs became evident.

(7) Determination of Fair and Reasonable Cost.

In accordance with FAR 15.404-1(b)(2)(ii), a fair and reasonable price will be determined by comparison of proposed prices to historical prices paid utilizing an extension of the FY 16 contract cost to repair 16 rotors on Trinity Unit 2 that was completed in May of 2018. The cost estimate to repair all 36 rotors on Trinity Unit 1 is estimated to be . Also, in accordance with FAR 15.404-1(c)(2)(iii), other than certified cost or pricing data as provided by the Contractor will also be analyzed to ensure fair and reasonable price.

(8) Description of Market Research Conducted.

There are three known companies with the capability to perform this work. They are GE Renewable Energy, Toshiba Energy Systems and Solutions Corp., and Voith Hydro, Inc.

Of the three firms, only Voith has recent experience with this type of work in this location. Voith has already prepared the relevant and site-specific submittals from the earlier Trinity Unit 2 project. They will not be required to generate new submittals for this work. Other firms must prepare these submittals, which will add several weeks to the performance timeline increasing risk significantly.

(9) Any Other Supporting Facts.

There are no additional facts to be reported in this section.

(10) Listing of Interested Sources.

No other parties have expressed an interest in this procurement and interest will not be solicited due to the extreme urgency.

(11) Actions Taken to Remove Barriers to Competition.

The Government will continue to conduct thorough market research to gauge the marketplace capabilities for future requirements. The Government will continue to seek competition of future acquisitions, but it is not possible when we are repairing critical infrastructure or property damaged by a natural disaster.

CONTRACTING OFFICER (CO) CERTIFICATION: (≤ $25K)

Date: 11/26/2018

Type Name: Signature:

CHIEF of the CONTRACTING OFFICE CONCURRENCE (CCO): (> $25K)

Date: 11/26/2018

Type Name: Signature:

BUREAU COMPETITION ADVOCATE: (> $700K)

Date: 12/4/2018

Type Name: Signature:

X Contracting Officer

X Chief of Contracting Office

X Bureau Competition Advocate

BUREAU PROCUREMENT CHIEF- If the CO and CCO are the same; the justification must be approved by one level above, which is the BPC

Date:

Type Name: Signature:

HEAD OF CONTRACTING ACTIVITY: (>$13.5M) - For the award of any non-competitive enterprise contract, a contract vehicle where orders or calls can be placed by or on behalf of multiple DOI bureaus, or which will be a mandatory source for DOI. (All Values)

Date:

Type Name: Signature:

SENIOR PROCUREMENT EXECUTIVE: (>$68M) - For the award of any single-award indefinite delivery vehicle (including blanket purchase agreements and all types of contracts outlined in FAR 16.5) with a ceiling price at or above $62.5M.

Date:

Type Name: Signature:

X Head of Contracting Activitiy

X Senior Procurement Executive

X Bureau Procurement Executive