HEAF Testing Facilities_OECD Part 2_JOFOC_Approved_04-13-2020.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

Date: April 10, 2020

MEMORANDUM TO: Jennifer Dudek, Contracting Officer

Operations Branch B Acquisition Management Division

FROM: Gabriel Taylor

Contracting Officer Representative, Office of Nuclear Regulatory Research

SUBJECT: ☐ LIMITED SOURCES JUSTIFICATION (LSJ)

☒ JUSTIFICATION FOR OTHER THAN FULL AND OPEN

COMPETITION (JOFOC)

REFERENCE: High Energy Arcing Faults Testing Facility and Services

“Source Selection Information – see FAR 2.101 and 3.104”

1. Nature and/or description of the action being approved.

a. Acquisition purpose and objectives.

The purpose of this work is to continue high energy arc fault (HEAF) testing to support two U.S. Nuclear Regulatory Commission (NRC) research initiatives; 1) generic issue program, and 2) international research agreement. Both initiatives require test data on high energy arcing fault phenomena to support hazard model advancements and improve the accuracy of fire probabilistic risk assessment methods. This acquisition will provide access to a high power testing laboratory to acquire the needed data and complete the testing campaign.

b. Project background.

HEAFs have the potential to cause extensive damage to the failed electrical component and distribution system along with adjacent equipment and cables within the zone of influence. The significant energy released during a HEAF event can act as an ignition source to other components. By better understanding the HEAF event hazard through testing, the NRC can advance the state of knowledge and support developing a model to adequately evaluate this hazard in performance-based applications.

NUREG/CR-6850 contains a model to evaluate HEAFs in cabinets, and the National Fire Protection Association (NFPA) 805 frequently asked question (FAQ) 35 contains a HEAF model for bus ducts. Each of these models is based primarily on a single event that corresponds to the type of failure; however, these models do not allow adjustments to account for variables that can influence hazards to adjacent critical equipment. To support improvement in state-of-the-art fire Probabilistic Risk Assessment (PRA) modeling of HEAF events, the NRC needs additional test data.

Additional test data will improve the state of knowledge and provide better characterization of HEAFs in the fire PRA and NFPA 805 license amendment request applications.

Previously, a test program was conducted between 2013 and 2016 to obtain data to support model advancements and in cooperation with international partners. These test programs support the Organisation for Economic Co-Operation and Development (OECD) Nuclear Energy Agency’s (NEA), “A Project to Characterize High Energy Arcing Fault Events.” As part of the international agreement, each participating country donated equipment to the NRC for testing. Following the testing performed between 2014 and 2016, additional equipment and needs for testing was identified.

In 2019, the NRC entered into an international agreement with eight countries to perform additional testing to collect vital data needed to advance understanding and methods to assess and characterize the risk of HEAF. The international agreement requires the NRC to act as the operating agent to perform 21 sponsored tests. In addition, the NRC plans to perform 15 additional tests that aim at resolving a pre-generic issue (pre-GI) related to HEAFs involving aluminum. To date, the NRC has completed four tests (under NRC Contract No. NRC-HQ-60-15-C-0004) and are planning an additional 4-6 tests (under NRC Contract No. 31310019C0011) that support the pre-GI program. The two programs (international and domestic) represent a multi-year initiative that may be modified as lessons are learned. This proposed acquisition will allow for 14 medium voltage and 12 low voltage tests.

This acquisition is a follow-on to work completed under NRC Contract No. NRC-HQ- 60-15-C-0004.

c. Name and address of the proposed contractor(s).

KEMA Powertest, LLC (DNV-GL) 4379 County Line Rd.

Chalfont, PA 18914-1825.

2. Description of the supplies or services required to meet the agency’s needs.

a. Project title.

HEAF Testing Facility and Services

b. Project description.

The purpose of this contract is to provide HEAF testing facilities and services. The test facility shall provide the electrical energy, thermal measurement instrumentation and data acquisition, electrical measurement, equipment preparation facilities, and testing facility to perform HEAF testing. The work required includes tasks that provide the following: on-site short term storage, on-site work preparation area, electrical arc test power supply and delivery system, testing cell, documentation of test results, ASTM thermal instrumentation and disposal of tested equipment.

c. Acquisition Information.

• Requirement type.

☐ Research & development (R&D) ☒ R&D support services ☐ Support services (non-R&D) ☐ Supplies/equipment ☐ Information Technology (IT) or Electronic and Information Technology (EIT) ☐ Construction ☐ Architect-engineer (A-E) services ☐ Design-build ☐ Other (specify): ____________________

• Type of action.

☐ New requirement ☒ Follow-on ☐ Other (specify): ______________________

• Proposed contract/order type.

☒ Firm-fixed-price ☐ Other fixed-price (specify, e.g., fixed-price award-fee, fixed-price incentive-fee): __________ ☐ Cost-plus-fixed-fee ☐ Other cost reimbursement (specify, e.g., cost-plus-award-fee, cost-plus-incentive-fee): ___________ ☐ Time and materials ☐ Labor Hours ☐ Indefinite delivery (specify whether indefinite quantity, definite quantity, or requirements): ___________

• Statement of Work Type ☒ Completion ☐ Level of Effort ☐ Performance Based

• Requisition number

RES-20-0078

• Total estimated dollar value and performance/delivery period.

The total estimated value is $815,235.00. The period of performance is estimated from July 1, 2020 through June 30, 2025.

3. Identification of the justification rationale.

☐ This acquisition is conducted under Federal Acquisition Regulation

(FAR) 8.405-6.

☐ Urgent and compelling need exists ☐ Only one source is capable of providing the supplies or services

(i.e., peculiar item, brand name item) ☐ Logical follow-on

☐ This acquisition is conducted under FAR 13.106-1(b).

☒ This acquisition is conducted under FAR 6.302- 1, Only one responsible source and no other supplies or services will satisfy agency requirements.

☐ This acquisition is conducted using Simplified Procedures for Certain Commercial Items pursuant to FAR 13.500.

☐ This acquisition is conducted using Simplified Procedures for Certain Commercial Items pursuant to FAR 13.500(c).

4. Description of the proposed contractor(s) unique qualifications to provide the required supply or service.

The required HEAF testing must be performed in an ISO 17025 accredited high power testing facility. All tasks require delivery of a high power electrical supply capable of providing three phase ac power. The voltage levels for each test shall be representative of the rating for the equipment being tested. The nominal operating voltage of equipment being tested shall be between 440Vac and 15,000Vac. The high power energy supply shall be capable of providing current capacity in the range between 10kA and 35kA at a nominal frequency of 60 Hertz. The test duration will be dependent on other test parameters, but be in the range of 2 to 8 seconds. Explicit voltage, current, X/R ratio, and fault time shall vary by the specific equipment tested. In addition, the testing area shall allow for combustion of target materials for time duration up to 10 minutes.

KEMA Powertest LLC is the only independent, high power testing facility that is capable of supporting high energy arc fault testing and whose facility policies allow the equipment to continue to burn for an extended period of time to allow for better characterization of the fire hazard. Further, KEMA Powertest LLC staff have developed their existing capability and have specialized skills and knowledge of their facility to uniquely qualify them to perform this work.

5. Description of the efforts made to ensure that offers are solicited from as many potential sources as practicable. Indicate whether a FedBizOpps notice was or will be publicized as required by FAR Subpart 5.2 and, if not, which exception under FAR 5.202 applies.

No other known facilities exist that meet NRC’s requirements for the HEAF testing.

Sources Sought Notice (SSN) No. 31310020R0021 was published on beta.SAM.gov on March 11, 2020 for 15 calendar days. No responses were received. Given the results of the SSN, a notice of intent to sole source was posted on the beta.SAM.gov on April 2, 2020 for 7 calendar days in accordance with FAR 5.203. No responses were received.

6. Description of the efforts made by the Contracting Officer (CO) to determine that the cost/price of the contract/order is fair and reasonable consistent with FAR 8.404(d) or 15.406-2.

In order to determine the proposed price is fair and reasonable, the CO compared the price proposed to the prices paid for services under NRC Contract Nos. NRC-HQ-60-15- C-0004 and 31310019C0011. The CO also performed a comparison to the Independent Government Cost Estimate.

7. Description of the market research conducted (see FAR Part 10) and the results, or a statement of the reasons market research was not conducted.

NRC Contract No. NRC-HQ-13-C-04-0012 was issued as a competitive commercial solicitation (Solicitation No. NRC-HQ-13-R-04-0011). KEMA was the only commercial source that provided a proposal to the solicitation. Following completion of Contract No.

NRC-HQ-13-C-04-0012, a high energy arcing fault power facility SSN was issued for NRC Contract No. NRC-HQ-60-15-C-0004. Responders to the SSN could not meet the requirements of that contracts. Prior to issuance of NRC Contract No. 31310019C0011 the NRC issued a notice of intent to sole source and did not receive any responses.

As noted above, for this requirement the NRC issued SSN No. 31310020R0021 on beta.SAM.gov on March 11, 2020. The SSN closed on March 25, 2020 and no responses were received. Given the results of the SSN, a notice of intent to sole source was posted on the beta.SAM.gov on April 2, 2020 for 7 calendar days in accordance with FAR 5.203. No responses were received.

The NRC COR conducted market research which included discussions with potential sources with industry experts. The NRC routinely conducts public meetings to communicate findings and plans for future testing. From these meetings, no source approached the NRC indicating that they had the capability to perform this work. From the performance of the market research, the NRC COR was unable to find any potential source other than KEMA Powertest LLC to perform the required work.

8. Other factors supporting the justification, if any.

Fulfilment of this work requires use of a specialized facility as well as specialized skills and knowledge that is only available at KEMA Powertest LLC. The testing work anticipated in this requirement will build on the lessons learned and data derived from the work performed under NRC-HQ-60-15-C-0004, and by virtue of their work on this previous testing, KEMA staff are uniquely qualified to perform the work. KEMA Powertest, LLC has built specialized incident energy calorimeters that reduce indirect heat conduction sources. This has resulted in a reduction to measurement uncertainty and increased research quality. KEMA Powertest, LLC has also redesigned the pressure measurement acquisition system to reduce electromagnetic interference during test exposures. This new system has greatly improved the signal to noise ratio of the measured data and increases research quality. Additionally, KEMA Powertest, LLC, has implemented data conservation procedures and system redundancies to reduce the likelihood of data loss.

9. List sources, if any, that have expressed an interest in the acquisition.

No other sources have expressed an interest in the proposed acquisition.

10. If applicable, describe the actions the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made.

N/A

11. Certifications

By signing below, the COR certifies that the justification is accurate and complete to the best of his or her knowledge and belief.

Contracting Officer Representative

Gabriel Taylor, Sr. Fire Protection Engineer Date Fire & External Hazards Analysis Branch Division of Risk Analysis Office of Nuclear Regulatory Research

This is to certify that the justification for the proposed acquisition has been reviewed and that, to the best of my knowledge and belief, the information and/or data provided to support the rationale and recommendation for approval is accurate and complete.

Contracting Officer

Jennifer Dudek, Contracting Officer Date Operations Branch B

CONCUR:

Competition Advocate

Nicole Stevenson, Acting Director Date

Office of Administration

Competition Advocate Date: 4/13/2020