Brand Name Justification S-Nickel signed.pdf

DEPARTMENT OF THE TREASURY

SF 1013 - JUSTIFICATION & APPROVAL FOR FAR SUBPART 13.5 SOLE SOURCE

(INCLUDING BRAND NAME) ACQUISITIONS

Treasury Standard Form – 1013 (Rev 5/18)

Prescribed by Treasury: DTAP 1013.501

1. Identification of the requiring activity and the contracting activity:

Department of the Treasury Bureau of Engraving and Printing (BEP) Office of Acquisition 14th and C Streets, SW Washington, DC 20228

Contracting Activity is for the acquisition of Raw Nickel Material for Electrolytic Plating 2.a Nature and/or description of the action being approved:

This is a Brand Name Justification and Approval under FAR Subpart 13.5 for the procurement of nickel “S” Pellets and “S” Rounds.

2.b Name of the vendor. N/A 2.c Requisition No.: N/A 2.d Bridge contract: Yes No 2.e Brand name: Yes No

3.a A description of the supplies or services required to meet the agency’s needs:

The Office of Engraving, Division of Plate Manufacturing, has a need to purchase raw nickel S-Pellets and S-Rounds to be used in electrolytic plating operations. The purpose of this acquisition is to procure Nickel S-Pellets and Nickel S-Rounds to the BEP for use in production of electroplated currency and miscellaneous plates. In both Facilities DCF and WCF, Electrolytic Nickel Anodes - "S" Rounds and S-Pellets shall be supplied in accordance with the attached Statement of Work.

Composition by Mass (as percentages) Round Buttons (2EG01145) Spherical Pellets (ENG1300)

Element Minimum Maximum Nickel 99.80 -- Sulfur 0.020 -- Iron 0.00 0.001

Copper 0.00 0.001 Carbon 0.00 0.005

3.b Includes IT: Yes No

3.c IGCE/Estimated dollar value:

$2,025,000.00 maximum for both facilities 5 years

4. Identification of the authority being used (Check the box that applies):

41 U.S.C. 1901 – Simplified acquisition procedures.

41 U.S.C. 1903 – Special emergency procurement authority.

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited:

BEP-OA -FY20JOFOC-0006

Treasury Standard Form – 1013 (Rev 5/18)

Prescribed by Treasury: DTAP 1013.501

Vale Americas (formally INCO) is the only manufacturer of Nickel S-Pellets and Nickel S- Rounds that adheres/passes to the stringent standard of Bureau of Engraving and Printing’s (BEP) Change Control Board (CCB) Verification and Validation (V&V) Level Two (2) testing process. This V&V level 2 testing is essential to BEP’s requirement to ensure that the electrolytic process is completed properly. The nickel plates are used directly in the printing of the BEP’s currency, which must function flawlessly in commerce. If a new grade of nickel is to be introduced in currency production, then it will have to undergo a Change Control Board (CCB) Verification and Validation (V&V) Level Two (2) test which is not in the best interest of the U.S. Currency Program. This test could take several months for completion and such a delay would impede and possibly shut down the currency production. Consequently, nickel that does not adhere to these specifications (due to growths, impurities, visual appearance or otherwise) run the risk of interfering with the performance of the plating process. Failure of new product to conform could result in as many as two hundred thousand (200,000) production currency sheets to be mutilated or damage to a press as a result of material failure. At this time, BEP has not identified other manufacturing sources that offer comparable product with similar quality to retain and guarantee BEP currency standards.

Therefore, BEP determine that Vale Americas is the only qualified manufacturer that will satisfy the agency’s unique requirements for the Nickel S-Pellets and Nickel S-Rounds.

6. A description of efforts to ensure that offers were solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by FAR subpart 5.2 and, if not, which exception under FAR 5.202 applies:

A request for information (RFI 2031ZA19B00018) was posted on FBO on October 22, 2019.

The BEP received responses from 4 vendors as of October 29, 2019, when the posting closed (Section 10 below).

This Brand Name Justification will be posted with the solicitation to express the Government intent to solicit this requirement on an item peculiar to one manufacturer basis.

7. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable:

The Contracting Officer anticipates the price will be fair and reasonable and will utilize pricing data and other price analysis techniques to make the determination. The contractor’s proposal will be evaluated using price analysis and determination of price fair and reasonableness will be made in accordance with FAR Part 13.106-3(a)(2)(ii) – Comparison with prices found reasonable on previous purchases and FAR Part 13.106-3(a)(2)(iv) – Comparison with similar items.

8. A description of the market research conducted (see FAR part 10) and the results or a statement of the reason market research was not conducted:

The contract specialist conducted the following actions:

Prescribed by Treasury: DTAP 1013.501

Reviewed prior acquisition history for similar or identical requirements: The procurement history for each previous purchase was pulled from BEN-Reporting. Analysis of these awards showed prices that appear to change more based on exchange rates on inflation, which is consistent with the rare variable of nickel. For more information please see Attachment D CLM History Report. This data also showed five Small Businesses that have provided the BEP this specific type of Nickel.

Contacted knowledgeable individuals in Government: Knowledgeable individuals were contacted on the prior history of Nickel procurement. Information received was prior knowledge on how the acquisition was procured and how often Nickel was placed under the simplified acquisition threshold. All previous actions were placed with small businesses that meet the bureau’s requirements. The BEP has been using electrolytic nickel over 20 years. Nickel has been purchased multiple times as small purchase orders. Procurement history includes historical data of 20 + years for Electrolytic Nickel.

Queried Government Database FPDS-NG was queried under NAICS Code 331491 and showed 1,384 results/reports. See below for all Government agencies listed in the FPDS report.

1,347 of the reports were with the Department of Defense but these awards were not for nickel used in electroplating currency related items, as a result this type of metal does not meet the BEP’s requirement.

22 of the reports were with the Department of Commerce, but these awards were not for nickel used in electroplating currency related items, as a result this type of metal does not meet the BEP’s requirement.

7 of the reports were with the Department of Interior, but these awards were not for nickel used in electroplating currency related items, as a result this type of metal does not meet the BEP’s requirement.

6 of the reports were with National Aeronautics and Space, but these awards were not for nickel used in electroplating currency related items, as a result this type of metal does not meet the BEP’s requirement.

1 of the reports was with the Department of Justice, but these awards were not for nickel used in electroplating currency related items, as a result this type of metal does not meet the BEP’s requirement.

1 of the reports was with the Department of the State, but these awards were not for nickel used in electroplating currency related items, as a result this type of metal does not meet the BEP’s requirement.

Prescribed by Treasury: DTAP 1013.501

Queried SBA: Conducted a SBA Small Dynamic search under NAICS code 331491. The search resulted in 106 small business profiles. However, after a careful review of the companies’ capabilities for providing the specific kind electrolytic nickel needed none were able to manufacture this nickel. After discussions with the program manager about the specifics of this requirement it was concluded that the small business companies’’ listed on SBA Dynamic search could not manufacture the Electrolytic Nickel for plating operations. Please see Attachment C-SBA Report for more details.

Queried GSA Advantage: GSA Advantage online shopping was queried for electrolytic nickel. This type of Nickel cannot be procured through GSA.

9.a Any other facts supporting this justification:

Please see below the historical data of other companies previously used by the BEP for Nickel S-Pellets and S-Rounds.

Item Number Award Number Award Amount Award Quantity

Award Price

Vendor Business Size Number of Employees

ENG1300 TEPA1534134 $64,800.00 24.00 2700.00 GASOCHEM

INTERNATIONAL LLC

Small Business

TEPA1634835 $22,400.00 8.00 2800.00 GASOCHEM

INTERNATIONAL LLC

Small Business

TEPA1635015 $22,400.00 8.00 2800.00 GASOCHEM

INTERNATIONAL LLC

Small Business

TEPA1635246 $123,970.00 70.00 1771.00 Constructors Interntl. Inc. Small Business

The most recent purchase was a Simplified Acquisition awarded on May 24, 2016, under award number TEPA16-35246. This acquisition was a small business set aside. This purchase was for seventy (70) 300lb drums of Vale S-Pellets with a total cost of $123,970.00.

The BEP Bureau of Engraving and Printing has used Vale America (formally INCO) as its sole nickel manufacturer but has purchased it through various small business resellers of nickel. Vale does not sell directly and there is a class waiver from the SBA for this NAICS code, 331491. Only Vale has been used because of the high purity nickel that is specifically manufactured for electroplating.

9.b Attachments: Yes No

10. A listing of sources, if any, that expressed, in writing, an interest in the acquisition:

As a result of RFI 2031ZA19B00018, four sources expressed interest in writing. They are:

Prescribed by Treasury: DTAP 1013.501

1. A Brite Company (which is a small business)

2. Specialized Metals (which is a small business)

3. Gasochem (which is a woman-owned small business)

4. Royal Imaging (which is a small business)

11. A statement of the actions, if any, the Requiring Activity or Contracting Activity may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required: Vale America will remain the approved manufacturer of Nickel to the Bureau until other viable sources demonstrate the capability to perform and supply the material compliant with BEP specifications in addition to getting approval through the Bureau Verification and Validation process; however, this Nickel can be resold amongst multiple resellers.

12. Certifications and Approvals:

12.a Program Office certification (Requiring Activity). I hereby certify that any supporting information and data provided, which form the basis for this justification, are accurate and complete to the best of my knowledge and belief.

Name: Date:

Signature:

12.b Contracting Officer certification and approval. I hereby determine the circumstances of this acquisition support the justification to acquire the item(s) on a sole source (including brand name) basis under the authority of FAR subpart 13.5. I also certify this justification is accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the authorized contracting officer for this acquisition, I hereby approve this justification.

Name: Date:

Signature:

13. Additional Reviews and Approvals (As applicable):

13.a Bureau Chief Information Officer or Authorized Designee (for IT requirements that are over $5 million, but not exceeding $68 million) (Contracting Activity). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief, and representative of the Government’s need. Therefore, I hereby consent to the approval of this justification. (Note: The Bureau CIO may delegate their authority for proposed contracts over $5 million, but not exceeding $13.5 million to the Associate Bureau CIO(s).)

Name: Date:

Signature:

13.b Advocate for Competition (if over $700,000, but not exceeding $13.5 million) (Contracting Activity). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the Advocate for competition, I hereby approve this justification.

Steven M. Olszowy 02/20/2020 Steven M. Olszowy Digitally signed by Steven M. Olszowy

Date: 2020.02.20 05:53:16 -05'00'

Antonio C. Sixon /0 /2020

Non-IT Requirement N/A

Antonio C. Sixon Digitally signed by Antonio C. Sixon Date: 2020.04.02 13:37:53 -04'00'

Prescribed by Treasury: DTAP 1013.501

Name: Date:

Signature:

13.c Head of the Procuring Activity or Authorized Designee (if over $13.5 million, but not exceeding $68 million) (Contracting Activity). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the head of the procuring activity or authorized designee, I hereby approve this justification.

Name: Date:

Signature:

13.d Treasury Chief Information Officer (for IT requirements that are over $68 million).

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief, and representative of the Government’s need. Therefore, I hereby consent to the approval of this justification.

Name: Date:

Signature:

13.e Senior Procurement Executive (if over $68 million) (Contracting Activity). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, as the senior procurement official, I hereby approve this justification.

Name: Date:

Signature: