Tab 4d_JnA_Redacted.pdf

August 2020

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIMPLIFIED ACQUISITION PROCEDURES (SAP) FAR 13.106-1(b)

SOLICITATIONS MAY BE LIMITED TO ONE SOURCE ONLY IF THE CONTRACTING OFFICER DETERMINES THAT ONLY ONE SOURCE IS REASONABLY AVAILABLE. THIS DETERMINATION MUST BE SUPPORTED WITH FULL JUSTIFICATION FOR SOLE SOURCE FROM THE CUSTOMER. WHEN THE CUSTOMER DESCRIBES AN ITEM WITH A PURCHASE DESCRIPTION WHICH LIMITS THE AVAILABILITY TO ONE SOURCE, THE JUSTIFICATION MUST EXPLAIN WHY THE ITEM IS THE ONLY ONE THAT WILL MEET THE GOVERNMENT’S REQUIREMENT. STATEMENTS SUCH AS "ONLY KNOWN SOURCE" OR "ONLY SOURCE WHICH CAN MEET THE REQUIRED DELIVERY DATE" ARE INADEQUATE TO SUPPORT A SOLE SOURCE PURCHASE. Do not use marketing language in this document. Language such as “This company has made its mark,” “This company is recognized as industry’s best,” and “This company is the leader in…” is unacceptable.

PURCHASE REQUEST OR REQUISITION

NUMBER

61200PR220079697

PROJECT/TASK

NUMBER

Unknown

ESTIMATED

AMOUNT: $

IDENTIFICATION OF THE AGENCY AND THE CONTRACTING OFFICE, AND SPECIFIC IDENTIFICATION OF THE DOCUMENT AS A “JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION.” PLEASE CITE THE

AUTHORITY AND TYPE OF JUSTIFICATION:

Department of Homeland Security (DHS), United States Coast Guard (USCG), United States Coast Guard Training Center (TRACEN) Petaluma, Petaluma, CA. Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by FAR 6.3 and in accordance with the requirements of FAR 6.303-1, the justification for the use of the statutory authority under FAR 6.3 is justified by the following facts and rationale required under FAR 6.303-2 as follows: The expeditious nature of this proposed action to properly dispose of the Hazardous Waste Class 3, Category 1, Extremely Hazardous Waste Ethyl Mercaptan is an Urgent and Compelling need for USCG TRACEN Petaluma. TRACEN Petaluma’s Environmental Protection Specialist (EPS) has contacted three (3) known HazWaste Disposal Companies and one (1) has provided a quote for his action, and the others, one (1) has not responded and the other one (1) is going to require more time to provide a quote and will not meet the urgency of the need for this pick-up and disposal, due to the impending warm temperatures that this region will face. The drum containing the Class 3 Category 1 Extremely Hazardous Waste Ethyl Mercaptan has shown signs of bulging from two (2) days of recently high temperatures in the high 80’s (which is unusual for this time of year in TRACEN Petaluma).

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED, AND THE INTENDED USE.

The proper disposal of this Extremely Hazardous Waste Ethyl Mercaptan, must be conducted and handled by a Certified and Licensed Hazardous Waste Disposal Company, with the proper permits, equipment and trained crew to transfer this Extremely Hazardous Waste Ethyl Mercaptan into special rated armored cylinders, for transport on the highways and streets, in an US Department of Transportation (USDOT) Permitted Hazardous Waste Transporter’s truck.

UNIQUE CHARACTERISTICS THAT LIMIT AVAILABILITY TO ONLY ONE SOURCE, WITH THE REASON NO OTHER

SUPPLIES OR SERVICES CAN BE USED.

Due to the urgency to have this 55 gallon drum fiber (plastic) containing the Ethyl Mercaptan, that is an extremely Hazardous Waste. Due to its Flash Point is Negative 54 Deg Fahrenheit and the Boiling Point is 95 Deg Fahrenheit and is required by USDOT regulations to be transported by a permitted and licensed Hazardous Waste Hauler. This Extremely Hazardous Waste Ethyl Mercaptan is currently being stored at the TRACEN Motor Pool building 171, which is a temporary Hazardous Waste holding room with explosion proof lighting and electrical outlets. This building is semi-isolated from the TRACEN general population and other buildings and structures. TRACEN Petaluma is concerned with the potential for a major mishap if this chemical were to become unstable and explode and catch fire.