FAR Part 13 JA W911SF25AA002 MCoE Hazmat redacted.pdf

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HAZARDOUS MATERIALS BPA
Solicitation number
MICC-2025-06
Issued by

About this file

This document is a Sole Source Justification and Approval (FAR 13.5) for a Blanket Purchase Agreement (BPA) with Lion's Club Industries (LCI) for the Maneuver Center of Excellence (MCoE) Hazardous Material Program. The procurement involves acquiring Class III packaged hazardous materials, including lubricants, cleaners, spray paint, sealing compounds, and corrosion prevention compounds necessary to support MCoE's Program of Instruction. The total contract value is $749,000.00, covering a 3-year period from approximately July 2025 to July 2028, with a base year and two option years.

The justification emphasizes that LCI is the sole source for these products due to the Logistics Readiness Center's Hazardous Material Control Center (HAZMART) operating exclusively with LCI at Fort Benning. The procurement is driven by environmental regulations, including EPA requirements and a presidential Executive Order to reduce hazardous material use. Market research was conducted, including a 15-day posting on Sam.gov with no alternative contractors expressing interest. The contract will be funded through Operations and Maintenance funds, and is intended to continue until a long-term solution is established with the Army Global Combat Support System (GCCS).

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ATTENTION

ATTENTION

Use this space to indicate categories, limited dissemination controls, special instructions, points of contact, etc., if needed.

1.

Controlled by: U.S. Army Controlled by: MICC-Fort Benning (CCMI-CEU-BN) CUI Category: SSEL Limited Dissemination Controls: FEDCON POC: Mr. Jason L. King, (706) 545-2408

All individuals handling this information are required to protect it from unauthorized disclosure.

Handling, storage, reproduction, and disposition of the attached document(s) must be in accordance with 32 CFR Part 2002 and applicable agency policy.

Access to and dissemination of Controlled Unclassified Infonnation shall be allowed as necessary and permissible to any individual(s), organization(s), or grouping(s) ofusers, provided such access or dissemination is consistent with or in furtherance of a Lawful Government Purpose and in a manner consistent with applicable law, regulations, and Government-wide policies.

Standard Form 901 (11-18) Prescribed by GSA/lSOJ I 32 CFR 200'2

CUI

Control No.: MICC 2025-06

Contractor: Lion's Club Industries (LCI) Program: Hazmat Class Ill packaged products

CUI

(Source Selection information - See FAR 2.101 and 3.104-4)

Apr 2021

JUSTIFICATION REVIEW DOCUMENT

FAR 13.5 SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS

SOLE SOURCE JUSTIFICATION AND APPROVAL

Program/Equipment: MCoE Fort Benning Hazardous Material Program has a requirement to procure Class Ill packaged hazardous material.

Authority: Simplified Procedures for Certain Commercial Items, 41 U.S.C. 1901 as implemented by FAR Subpart 13.5.

Amount: $749,000.00

Prepared by: Krista M. Spencer Contract Specialist Email: Krista. M. Spencer.civ@army.mil

Contracting Officer: Shannon J. Hutchins Contract Officer Email: Shannon.j.hutchins.civ@army.mil

Technical: Jennifer Duval

Deputy Director Email: Jennifer.A.Duval.civ@army.mil

Requirements: Johnny R.Knowles

COR

Email: johnny.r.knowles.civ@army.mil

DSN: 669-5271

Date: 28 May 2025

DSN: 835-2430

DSN: 835-0677

DSN: 835-5218

Reviews: I have reviewed this justification and find it adequate to support sole source.

Program Manager:

Jennifer Duval DSN: 835-0677

DUVAL.JENNIFER.ANN.

1048383692

Digitally signed by

DUVAL.JENNIFER.ANN.1048383692

Date: 2025.05.28 16:36:34 -04'00' Date: See digital signature mailto:Krista.%20M.%20Spencer.civ@army.mil mailto:Shannon.j.hutchins.civ@army.mil mailto:Jennifer.A.Duval.civ@army.mil mailto:johnny.r.knowles.civ@army.mil

Contractor: Lion's Club Industries (LCI) Program: Hazmat Class Ill packaged products

CUI

(Source Selection information - See FAR 2.101 and 3.104-4)

Small Business Specialist, Small Business Program:

Paul 0. Waite DSN: 826-8199

Digitally signed by

WAITE.PAUL.ORLINGTON.1015243

GTON.1015243208 208

Date: 2025.06.02 08:12:40 -04'00'

Legal Counsel:

Date: See digital signature

KELLEY.CHRISTOPHE

R.ROBIN.1260594911

Digitally signed by

KELLEY.CHRISTOPHER.ROBIN.1260

594911 Date: 2025.08.05 08:31:03 -04'00'

DSN: 835

Contracting Office Division Chief:

Shannon Hutchins

Director, MICC-(office):

Mr. Jason L. King

DSN: 835-2430

DSN: 835-2408

KING.JASON.L.12

82596861

Digitally signed by

KING.JASON.L.1282596861

Date: 2025.08.05 11:49:45 -04'00'

HUTCHINS.SHANNON.J Digitally signed by

.1383496965

HUTCHINS.SHANNON.J.1383496965

Date: 2025.06.09 12:14:16 -04'00'

WAITE.PAUL.ORLIN

Contractor: Lion's Club Industries (LCI) Program: Hazmat Class Ill packaged products

CUI

(Source Selection information - See FAR 2.101 and 3.104-4)

FAR 13.5 Simplified Procedures for Certain Commercial Items

Sole Source Justification and Approval

1. Contracting Activity: U.S. Army Mission and Installation Contracting Command (MICC)-Fort Benning, 6650 Meloy Drive Suite 250 Fort Benning, GA 31905-1319.

2. Description of Action: Maneuver Center of Excellence (MCoE), Directorate of Training Sustainment (DOTS) requests a new Blanket Purchase Agreement (BPA) with Lion's Club Industries (LCI) that runs the Centralized Hazmat Control Center Centralized (HAZMART) on Sand Hill. The Government projects award for July 2025 and fiscal year 2025, Operations and Maintenance funds will be used.

An acquisition plan is not required because this procurement does not meet the threshold at Defense Federal Acquisition Regulation Supplement 207.103(d)(i)(B).

This action is a follow-on to contract W911SF23A0004. That contract was not competed under authority FAR 13.106-1(b)(1): Soliciting from a single source. Paragraph, "Actions to Increase Competition" of the previous justification, stated: For purchases not exceeding the simplified acquisition threshold (SAT), only one source reasonably available, urgency, exclusive licensing agreements, brand name, or industrial mobilization.

3. Description of Supplies/Services: DOTS has a requirement to procure Class Ill packaged products (hazardous materials). These products include items such as lubricants, cleaners, spray paint, sealing compounds and corrosion prevention compounds necessary to support MCoE's Program of Instruction.

Base Period: 10 July 2025 to 9 July 2026 Option Period 1: 10 July 2026 to 9 July 2027 Option Period 2: 10 July 2027 to 9 July 2028

Value: $ 249,666.00 Value:$ $249,666.00 Value: $ 249,666.00

Total Value: $ 749,000.00

4. Authority Cited: 41 U.S.C. 1901; Simplified Procedures for Certain Commercial Items as implemented by FAR Subpart 13.5.

5. Reason for Authority Cited: As described at FAR 13.5), this subpart authorizes the use of simplified procedures for the acquisition of supplies and services in amounts greater than the simplified acquisition threshold but not exceeding $7.5 million ($15 million for acquisitions as described in 13.500(c)), including options, if the contracting officer reasonably expects, based on the nature of the supplies or services sought, and on market research, that offers will include only commercial items.

Contractor: Lion's Club Industries (LCI) Program: Hazmat Class Ill packaged products

CUI

(Source Selection information - See FAR 2.101 and 3.104-4)

This BPA is required until a long-term solution is established with the Army Global Combat Support System (GCCS). The unit's government purchase card (GPC) is not authorized due to requirements would exceed the (GPC) purchasing monthly purchase limit for supplies, and this is a recurring requirement. In accordance with the Logistics Readiness Center Supply Division Hazardous Material Control Center (HMCC) External Standard Operating Procedure (ESOP), LRC Memorandum of Agreement (MOA) with LCI, Environmental Protection Agency (EPA) regulations, Hazardous Material Management Program (HMMP) and MCoE Hazardous Waste Management Plan, an organization cannot purchase hazardous materials from any other place than the HAZMART on Sand Hill. HAZMART only sells items from LCI. Therefore, since DoTS has to purchase hazardous materials from HAZMART on Sand Hill, and HAZMART only sells items from LCI, LCI must be the sole source.

The Garrison Commander has directed a Hazardous Material Control Program to be implemented at Fort Benning due to the reporting requirements by the Environmental Protection Agency (EPA) and a presidential Executive Order (EO) to reduce hazardous material used by the Federal Government. The Hazardous Material Management Program (HMMP) tracks hazardous material throughout its life cycle. The Resource Conservation and Recovery Act (RCRA) requires that hazardous waste (HW) be managed from their inception (cradle) to their ultimate point of disposal (grave). The purpose of this is to prevent HW from reaching the environment and to minimize, if not eliminate exposures to hazardous material. LCI has a Memorandum of Agreement (MOA) with Logistics Readiness Center (LRC) to operate, provide the management, supervision, personnel, and inventory necessary to support customers in its daily operations at the HAZMART at Fort Benning. A delay in these services would services would severely impact the Fort Benning mission.

6. Efforts to Obtain Competition: None. Competition for this BPA is not possible due to the Logistics Readiness Center Supply Division Hazardous Material Control Center (HMCC) External Standard Operating Procedure (ESOP), LRC Memorandum of Agreement (MOA) with LCI, Environmental Protection Agency (EPA) regulations, Hazardous Material Management Program (HMMP) and MCoE Hazardous Waste Management Plan.

7. Actions to Increase Competition: None. Competition for this BPA is not possible due to the Logistics Readiness Center Supply Division Hazardous Material Control Center (HMCC) External Standard Operating Procedure (ESOP), LRC Memorandum of Agreement (MOA) with LCI, Environmental Protection Agency (EPA) regulations, Hazardous Material Management Program (HMMP) and MCoE Hazardous Waste Management Plan.

8. Market Research: Due to the nature of these supply products, the only authorized

Contractor: Lion's Club Industries (LCI) Program: Hazmat Class Ill packaged products

CUI

(Source Selection information - See FAR 2.101 and 3.104-4) vendor to purchase Class Ill packaged products for Fort Benning is LCI. Market research was conducted. Notice of intent to sole source was posted to Sam.gov for 15 days; no contractors provided interest in the posting.

9. Interested Sources: To date, no other sources have written to express interest in the acquisition.

10. Other Facts:

a. Procurement History:

Contract number: W911SF-21-A-1002 Vendor: LC Industries Inc.

Award date: 14 April 2021 Competitive Status: Sole Source Justification Authority cited: 41 U.S.C. 1901; Simplified Procedures for Certain Commercial Items as implemented by FAR Subpart 13.5.

Contract number: W911SF-22-A-0001

Award date: 27 April 2022 Competitive Status: Sole Source Justification Authority cited: FAR 13.106-1(b)(1): For purchases not exceeding the simplified acquisition threshold (SAT), only one source reasonably available, urgency, exclusive licensing agreements, brand name, or industrial mobilization.

Contract number: W911SF-23-A-0004

Award date: 10 July 2023 Competitive Status: Sole Source Justification Authority cited: FAR 13.106-1(b)(1): For purchases not exceeding the simplified acquisition threshold (SAT), only one source reasonably available, urgency, exclusive licensing agreements, brand name, or industrial mobilization.

11. Technical Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Jennifer Duval Deputy Director

ANN.1048383692 92

Contractor: Lion's Club Industries (LCI) Program: Hazmat Class Ill packaged products

CUI

(Source Selection information - See FAR 2.101 and 3.104-4)

12. Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Johnny R. Knowles

COR

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable.

This determination will be made using the price analysis and IGCE.

As a part of this basis, certified cost or pricing data is not required because the item and/or services being acquired are considered commercial.

HUTCHINS.SHANNON.

J.1383496965

Shannon J. Hutchins Contracting Officer

Digitally signed by

HUTCHINS.SHANNON.J.1383496965

Date: 2025.06.09 12:15:11 -04'00'

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

HUTCHINS.SHANNO

N.J.1383496965 Shannon J. Hutchins Contracting Officer

Digitally signed by

HUTCHINS.SHANNON.J.1383496965

Date: 2025.06.09 12:15:45 -04'00'

KNOWLES.JOHNNY.RAY.10564 Digitally signed by

70200

KNOWES.JOHNNY.RAY.1056470200

Date: 2025.05.29 08:46:21 -04'00'

Contractor: Lion's Club Industries (LCI) Program: Hazmat Class Ill packaged products

CUI

(Source Selection information - See FAR 2.101 and 3.104-4)

Approval

Based on the foregoing justification, I hereby approve the procurement of Hazardous Material Class Ill packaged products on a sole source basis pursuant to the authority of the Simplified Procedures for Certain Commercial Items, Title 41 United States Code Section 1901 as implemented by Federal Acquisition Regulation 13.5. The estimated value of the contract is $749,000.00 for a 3-year period of performance consisting of a base year and two option years, from approximately July 20225 through approximately July 2028. The approval is subject to availability of funds, and provided that the services or supplies herein described have otherwise been authorized for acquisition.

Digitally signed by

HUTCHINS.SHANNON.J.13834969

ON.J.1383496965

Shannon J. Hutchins Contracting Officer

HUTCINS.SHANN

Authority: Simplified Procedures for Certain Commercial Items, 41 U.S.C. 1901 as implemented by FAR Subpart 13.5.
Email: Krista. M. Spencer.civ@army.mil
Contract Officer
Email: Jennifer.A.Duval.civ@army.mil
DSN: 669-5271
DSN: 835-2430
DSN: 835-0677
DSN: 835-5218
Date: 28 May 2025
Jennifer Duval DSN: 835-0677
Paul 0. Waite DSN: 826-8199
Date: See digital signature
DSN: 835
Date: See digital signature
Shannon Hutchins
Mr. Jason L. King
DSN: 835-2430
Date: See digital signature DSN: 835-2408
Date: See digital signature

ON.J.1383496965

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