Fair Opportunity JA RH OM GAC System_Final_redacted.pdf

DEPARTMENT OF THE NAVY

NAVAL FACILITES ENGINEERING SYSTEMS COMMAND PACIFIC

258 MAKALAPA DR STE 100

JBPHH HI 96860-3134

January 2025

Justification for an Exception to Fair Opportunity

J&A No.

1. AGENCY AND CONTRACTING ACTIVITY: This is a Justification for an Exception to Fair Opportunity. The requiring activity is the Navy Closure Task Force (NCTF) Red Hill. The contracting activity is Naval Facilities Engineering System Command (NAVFAC), Pacific.

2. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED: This justification is for the award of a sole source, Firm-Fixed-Price Task Order under contract number N62742-24-D-3500 Global Contingency Services Multiple Award Contract III (GCSMAC III) to Vectrus System Corporation (V2X).

3. DESCRIPTION OF REQUIRED SUPPLIES/SERVICES: The proposed acquisition is to provide operations and maintenance (O&M) for the existing Granulated Activated Carbon (GAC) and Ion Exchange (IX) resin treatment system at the Red Hill Bulk Fuel Storage Facility (the Facility) on the Island of Oahu, for a base period of one year with three option years, as well as one 6-month option for updated GAC system pilot study. The primary focus is to ensure the continuous treatment and supply of potable water through a combination of GAC and IX resin technologies designed to remove total petroleum hydrocarbons (TPH) and per- and polyfluoroalkyl substances (PFAS) contaminants. The treated water system supports both discharge and reuse for cleaning operations at Red Hill, with maintenance of the water truck filling station to supply treated water during closure activities. The sole source contractor is V2X and the estimated task order value is

If the GAC/IX pilot study option is exercised, the pilot study will occur during the operations and maintenance (O&M) of the GAC/IX system and will evaluate the water quality at the Facility in order to identify the optimal solution for removing contaminants, including TPH and PFAS, specific to the Red Hill Aquifer water.

The original existing GAC/IX system was installed by V2X under GCSMAC II contract, task order N62742-22-F-4010 with a completion date on June 2022. Due to the ongoing requirement NCTF, two task orders were issued under the GCSMAC II contract in order to continue the O&M at the facility. Under the current task order N62742-23-F-4030, V2X is actively leasing the GAC/IX tanks and performing O&M of the Facility, with a period of performance (PoP) end date of 09 September 2025.

258 MAKALAPA DR STE 100

JBPHH HI 96860-3134

January 2025

4. IDENTIFICATION OF THE EXCEPTION TO FAIR OPPORTUNITY: The statutory authority which permits exception to fair opportunity to be considered for each order over the micro-purchase threshold issued under a multiple award contract is 10 U.S.C. 3406(c), as implemented by FAR 16.505(b)(2)(i) (A-G):

The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays

Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized

The order-must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order

It is necessary to place the order to satisfy a minimum guarantee

For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that purchase be made from a specified source

Set aside orders for any of the small business concerns identified in 19.000(a)(3) in accordance with section 1331 of Public Law 111-240 ( 15 U.S.C. 644(r))

The order satisfies one of the exceptions permitting the use of other than full and open competition listed in 6.302

5. RATIONALE/EXPLANATION TO SUPPORT CITED AUTHORITY: This justification is based on the determination that only V2X possesses the unique and highly specialized knowledge to successfully conduct the continued O&M of the treatment system at the Red Hill Shaft and perform the updated GAC/IX system pilot study.

V2X is currently on-site and has developed strong professional relationships over the past several years with both military and civilian personnel, all of which have been essential in ensuring the efficient day-to-day O&M activities with the existing GAC/IX systems at the Facility. Through this work, V2X has gained specialized experience with the current systems under actual field conditions that is not readily available from other contractors. The GAC/IX system components required for this treatment system are not standard, off-the-shelf items, but were specifically designed and custom-built for the Facility, tailored to the site's unique water quality characteristics and end-use requirements. This customization necessitated multiple discussions, drawing iterations, and close collaboration with the manufacturer, involving custom fabrication and material selection to ensure the components could withstand the specific conditions and meet stringent drinking water standards.

258 MAKALAPA DR STE 100

JBPHH HI 96860-3134

January 2025

Due to this combination of historical knowledge, site-specific expertise, and forward-looking system integration capabilities, V2X is the only contractor possessing the requisite expertise to perform the GAC/IX pilot study at the Red Hill Facility. V2X was the original installer of the existing GAC/IX treatment system under GCSMAC II task order N62742-22-F-4010 and currently provides O&M services under task orders N62742-23-F-4030. This direct, hands-on experience has provided V2X with a comprehensive understanding of the system's design parameters, operational performance, and the specific water quality characteristics of the Red Hill Aquifer, including TPH and PFAS contaminants. Because the pilot study will directly inform and integrate with the existing GAC/IX system's O&M, engaging an alternate contractor would necessitate a significant period of system familiarization, potentially disrupting ongoing water treatment efforts and increasing costs. Therefore, utilizing V2X's established expertise is essential to ensure a seamless, efficient, and effective pilot study focused on identifying the optimal long-term solution for contaminant removal specific to the Red Hill Aquifer.

For the reasons stated above, in order to sustain ongoing groundwater remediation efforts at the Red Hill Bulk Fuel Storage Facility and associated Navy installations, the Navy must award this task order to V2X, utilizing the aforementioned authority. Failure to do so would leave the Navy without a viable mechanism to maintain treatment and distribution systems in optimal operational condition, ensure compliance with Hawaii Department of Health (HDOH) and Environmental Protection Agency (EPA) facility closure requirements, and ultimately, safeguard the availability of treated water as a reliable source for Joint Base Pearl Harbor-Hickam (JBPHH) and associated Navy housing areas.

6. FAIR AND REASONABLE COST DETERMINATION: To ensure the proposed task order offers the best value to the Government, the Contracting Officer will determine a fair and reasonable price using the cost and price analysis procedures outlined in FAR 15.404-1. The Government will utilize historical pricing data from prior GCSMAC III task orders, modifications, and independent government estimates to conduct this analysis. Following approval of the Justification for an Exception to Fair Opportunity, a Request for Proposal (RFP) will be issued to V2X. V2X will then be required to submit a Certificate of Current Cost or Pricing Data, as mandated by FAR 15.403-4(a)(1).

7. ANY OTHER FACT SUPPORTING THE JUSTIFICATION: The GAC/IX treatment system at the Facility is critical to support and sustain ongoing groundwater remediation efforts at the Red Hill Bulk Fuel Storage Facility and associated Navy installations and maintaining all treatment and distribution systems in optimal operational condition. Any disruption in the Facility nt impacts on the readiness of our military forces.

Therefore, a sole source award to V2X represents the most prudent and advantageous course of

-quality services in a timely and cost-effective manner, makes them uniquely positioned to ensure the successful operation of this critical infrastructure and safeguard the health and readiness of our military forces.

258 MAKALAPA DR STE 100

JBPHH HI 96860-3134

January 2025

Furthermore, awarding this task order to any other entity would require complete system familiarization, an operational/initialization work plan, and approvals from HDOH, all of which would delay the start of full-scale O&M at the Facility. This entire process involving research, installation, and maintenance could potentially cost over , comparable to the combined expenses incurred under task orders N62742-22-F-4010 ( ) for the initial research and installation; task order N62742-22-F-4023 ( ) for O&M; task order N62742-23-F-4030 ( ) for the ongoing O&M until September 2025.

Upon approval of this J&A, NAVFAC Pacific will issue a Request for Proposal to V2X. This justification shall be made publicly available within 14 days after contract award to satisfy 10 U.S.C. 2304(1).

8. ACTIONS TO INCREASE COMPETITION: This project will provide immediate resiliency to the JBPHH water distribution system until the Red Hill Shaft is fully restored. At that time, the requiring activity will make a determination regarding the future of the Facility. If a follow on project is required and approved by HDOH, a permanent system will be designed and installed to provide drinking water on a consistent basis. This project would be competitively procured.

258 MAKALAPA DR STE 100

JBPHH HI 96860-3134

ECHELON II DIVISION DIRECTOR ENDORSEMENT

Signature:

Name/Title:

ASSISTANT COMMANDER FOR CONTRACTING APPROVAL

Upon the basis of the above justification, I certify that this justification is accurate and complete to best of my knowledge and belief and hereby approve the Exception to Fair Opportunity for the proposed procurement(s) described herein using pursuant to the 10 U.S.C. 3406c, as implemented by FAR 16.505(b)(2).

Signature:

Name/Title: