A.02.06 Brand Name Determination KTR.pdf

Control No. 21-0047

BRAND NAME DETERMINATION

OPTO-22 EQUIPMENT

1. CONTRACTING AGENCY:

Walla Walla District, U.S. Anny Corps of Engineers, Contracting Division, 201 North Third Avenue, Walla Walla, WA 99362.

2. DESCRIPTION OF ACTION:

Approval is requested for Other Than Full and Open Competition for procuring Opto-22 Brand Name products. The Opto-22 products listed below are critical components which will serve as modifications to the existing GDACS system for Lower Monumental Dam.

3. DESCRIPTION OF SUPPLIES/SERVICES OR NATURE OF CONSTRUCTION:

The supplies listed below are to be implemented into cunent control systems for the Generic Data Acquisition Control Systems (GDACS). These supplies will meet the Intrnsion Detection Systems requirements by DOD 8500.2. This purchase is for the installation of GDACS, Opto-22 has provided pricing as shown below for required items:

Manufacturer Part Number Description Estimated Qty Total Cost Cost Per Total

Unit

Opto-22 SNAP-PAC-RCK-16 16 Rack Backplane 31

Opto-22 SNAP-PAC-EB2 Ethernet Module 31

Opto-22 SNAP-PSS l l0VAC to SV 31 Power Supply

Opto-22 SNAP-AIV-I 3 l Input Module

Opto-22 SNAP-AIMA-I 0-20 mA Al 29

Module Opto-22 SNAP-IACS 90-140 VACNDC 193

Input Module Opto-22 SNAP-AIRTD-10 3 Wire 10 Ohm 78

RTD Analog Temp Inout

Opto-22 SNAP-OACS 12-250VAC Digital 9 Outout Module

Opto-22 SNAP-ODCSA-i 5-200 VDC 25 Discrete Output Module

Opto-22 SNAP-TEX-CBS6 Straight Through 96 Connector

Opto-22 SNAP-TEX-CBO6 Jumpered (Neutral) 150 Collllector

Opto-22 SNAP-STRAPB 6 Connector

4. AUTHORITY CITED:

FAR 13.106-1(b) (1) Soliciting from a Single Source. For purchases not exceeding the simplified acquisition threshold, Contracting Officer’s may solicit from one source if the contracting officer determines that the circumstances of the contract action deem only one source reasonable available.

5. REASON FOR AUTHORITY CITED:

a. Background: The equipment requested will be used for replacing End Of Life components at Lower Monumental Dam for the Opto-22 Upgrades project for Walla Walla district. The Brand Name equipment requested will be used as part of the existing control system for the GDACS to provide an Intrusion Detection System (IDS) required by DOD 8500.2. GDACS is the automated power plant monitoring and control system for controlling power generation from Corps Northwestern Division (NWD) hydropower plants and other federal power plants that may be linked to the NWD.

b. Justification: Only Opto-22 name brand items are compatible with existing equipment that is used to communicate to the existing network. It is required for continued security of critical infrastructure or protected systems to resist interference, compromise, or incapacitation.

c. Impact: Any cyber intrusion of GDACS hardware or software could cripple the Pacific Northwest power supply network, managed by the Bureau of Reclamation (BOR), Bonneville Power Administration (BPA), and the Corps of Engineers (COE) through the common Federal Columbia River Power System (FCRPS). As a result, access to GDACS cannot be provided to a wide range of competitors for GDACS support services due to potential cyber security risk and requirements. The cost, time, and effort to build alternative GDACS systems made from non-standardized hardware or software would be prohibitive and incompatible to essential operational needs. If it was decided to replace current non-standard components from multiple vendors or one vendor this would have to be replicated at all FCRPS projects to ensure GDACS compatibility and continued communication among plants. It is essential to purchase the brand name equipment in order to comply with DOD 8500.2 and ensure IDS is installed at Lower Monumental Lock and Dam.

The current GDACS system is multi-vendor (e.g., OPTO 22, Cisco, SoftPLC, and others) but each provides specific parts of system. Due to cybersecurity concerns and the risk of large-scale impacts to power production only established vendors can provide the components needed to maintain GDACS and any purchase for GDACS has to comply with the GDACS Purchasing Guide.

d. Alternatives:

Not Purchase – this alternative is not feasible because we need to ensure the availability of a working and usable sequence of Opto-22 products at the projects where GDACS is installed.

Purchase a different name brand – this alternative is not in the best interest of the US Army Corps of Engineers because of the additional cost that would be incurred with installing non-Opto-22 products due to compatibility with other components of GDACS.

Reconfiguring GDACS at all plants to accommodate other vendors would necessitate changes at all FCRPS plants. Changes at this scale would likely be millions of dollars but currently hasn’t been quantified.

6. EFFORTS TO OBTAIN COMPETITION:

The Lower Monumental Powerhouse configuration requires use of these specified items for the continued operation of the GDACS system for Lower Monumental and the entire GDACS system on the mainstem dams of the Columbia and Snake Rivers. Due to the need for compatibility of existing equipment, it is essential that we replace components with Opto-22 products. To replace the brand name supply with an equivalent supply would result in higher administrative costs, subsequent longer time to resolution and create the potential for intrusion.

7. ACTIONS TO INCREASE COMPETITION:

More than one source can provide the Opto-22 supplies.

8. MARKET RESEARCH:

Research shows Opto-22 brand name products is the only identified product compatible with the existing system for this installation phase. Other sources have been vetted to meet current needs, but there is no alternative available without complete system replacement with an equivalent product.

9. INTERESTED SOURCES:

One vendor that is an authorized distributor has expressed an interest and provided competitive pricing.

CONTRACT SPECIALIST: I certify that the information supporting this brand name determination is accurate and complete to the best of my knowledge based on the supporting data provided by technical or requirements personnel.

Prepared by: Nathan Bruce Title: Contract Specialist

DETERMINATION: In accordance with the authority of 10 U.S.C. 2304(c)(1), as implemented by FAR 13.106-1 (b) and based upon the foregoing, I hereby determine that a brand name procurement is authorized and is in the best interest of the Government.

Approved by: Jani Long Title: Contracting Officer

LEGAL REVIEW: I determine that I have reviewed this requirement and concur with the Brand Name Determination.

Approved by: Theresa Hampson Title: Attorney