JA 22-03 Rockwell A-B Ft Kam Clarifiers1_Redacted.pdf

DEPARTMENT OF THE NAVY

NAVAL FACILITIES ENGINEERING COMMAND, HAWAII

400 MARSHALL ROAD

JBPHH, HAWAII 96860-3139

J&A No. 22-03

JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

SOLICITATION WORK ORDER NUMBER (WON) 1629039, OVERHAUL PRIMARY AND

SECONDARY CLARIFIERS, JOINT BASE PEARL HARBOR HICKAM, PEARL HARBOR,

OAHU, HAWAII

1. Contracting Activity.

Naval Facilities Engineering Command, Hawaii (NAVFAC HI), Architect- Engineer Acquisition Division, Joint Base Pearl Harbor Hickam (JBPHH).

2. Description of the Action Being Approved.

Request approval for the use of Allen-Bradley MicroLogix 1400 Programmable Logic Controller (PLC) and Allen-Bradley 1762 Series Input/Output (I/O) Module, manufactured by Rockwell Automation, 1201 S 2nd Street, Milwaukee, WI, 53204, for Work Order Number 1629039, Overhaul Primary And Secondary Clarifiers, JBPHH, Pearl Harbor, Oahu, Hawaii.

3. Description of Supplies/Services.

The general scope of work of the Overhaul Primary and Secondary Clarifiers project is to replace the primary and secondary clarifiers and its associated controls at the Fort Kamehameha Wastewater Treatment Plant (WWTP). The scope of work includes connecting all new equipment to the existing WWTP Supervisory Control and Data Acquisition (SCADA) system.

A SCADA system is a centralized control system that utilizes computers, networked data communications, and graphical user interfaces to monitor and control certain devices in a system, such as clarifiers and pump motors in the WWTP SCADA system. SCADA systems typically implement a tag database. Each “tag” is a point of data the system monitors. An industrial network switch is used in a SCADA system to connect devices using telecommunications cables. The industrial network switch allows each connected device to interface with the other switches.

This project will require new PLCs and I/O modules at the new clarifier equipment for monitoring and control. This project will require connecting all new equipment to the existing WWTP SCADA system, which includes existing Allen-Bradley controllers.

The total estimated value for the use of Allen-Bradley PLCs and I/O modules is as follows:

4. Statutory Authority Permitting Other Than Full and Open Competition.

This request is submitted pursuant to the authority of 10 U.S.C.

2304(c)(1), only one responsible source and no other supplies or services will satisfy agency requirements.

5. Rationale Justifying Use of Cited Statutory Authority.

The Allen-Bradley equipment shall be used due to: 1) the functional compatibility with the existing WWTP SCADA system, 2) the maintenance efficiencies with standardized equipment, and 3) to align the project with the existing WWTP SCADA system authority to operate (ATO) requirements.

1) Functional Compatibility

The new PLCs and I/O modules must be able to integrate and communicate with the existing Allen-Bradley PLCs currently installed in the WWTP SCADA system.

PLCs and I/O modules from manufacturers other than Allen-Bradley are not known to be directly compatible with the existing Allen- Bradley PLCs. Two potential alternate sources were provided by respondents to a sources sought notice: Emerson and Siemens.

The respondent who provided as an alternate source specifically noted that the could not directly integrate and communicate with Allen-Bradley PLCs unless an additional device is installed between the two units. would require unique programming to translate the communication between one manufacturer’s PLC and the other manufacturer’s PLC. Adding a will: 1) increase the potential for failure of the SCADA system by introducing additional hardware and programming into the system, and 2) create an additional maintenance burden as there is currently no requirement for maintenance expertise in data communication translation.

The respondent who provided as an alternate source only provided a cut sheet for a , which did not indicate how the specific part could communicate with Allen-Bradley PLCs.

The Government performed market research on the internet, and it appears that it is not possible for a to directly integrate and communicate with an Allen-Bradley PLC. Additional equipment and programming would be required to translate different communications protocols between the two different manufacturer devices. Adding additional devices will: 1) increase the potential for failure of the SCADA system by introducing additional hardware and programming into the system, and 2) introduce an additional maintenance burden as there is currently no requirement for maintenance expertise in data communication translation.

2) Standardized Equipment for Maintenance

Avoid the significant operational burden and additional training costs for the maintenance and engineering staff to become proficient with the configuration, programming, commissioning, operation, and maintenance of controllers from different manufacturers. Additionally, standardization decreases procurement costs related to additional equipment, maintenance, and support contracts for another manufacturer’s hardware and software, and reduces the maintenance of an additional parts inventory. Maintaining multiple solutions is inefficient and creates unnecessary work and overhead that increases the total costs of ownership and manpower costs.

3) ATO Requirements

The WWTP SCADA system is required to meet UFC 4-010-06 cybersecurity requirements and maintain its existing Authority to Operate (ATO) through the Risk Management Framework (RMF) process. This is a shared responsibility between Utilities Management (UM) and NAVFAC CIO.

Allen-Bradley PLC and I/O module devices are currently included within the existing WWTP ATO and are already installed within the system. Additionally, the Allen-Bradley equipment is included within the current WWTP ATO. The proposed Emerson and Siemens PLCs are not approved by the existing ATO.

Assuming other brand name PLCs could be integrated into the installations existing WWTP SCADA system so as to be fully functional, the additional costs associated with the Government to include additional manufacturer PLC and I/O devices to the existing ATO, and other disadvantages arising from the use of different brands of

Programmable Logic Controllers (PLCs) and Input/Output (I/O) Modules outlined above are not expected to be recovered through competition.

6. Description of Efforts Made to Solicit Offers from as Many

Offerors as Practicable

Market research indicates other manufacturers that produce PLCs and I/O modules are However, the Government’s understanding is that the 3 issues noted in paragraph 5 would be applicable to any devices other than Allen-Bradley, and therefore Allen-Bradley PLCs and I/O modules should be provided for the WWTP SCADA system.

In accordance with FAR 5.2, a Sources Sought Notice (No.

N62478ACQ33FY2201) was posted on 13 January 2022 on the sam.gov website. The sources sought requested all interested parties respond within 15 days after the date of the publication of the synopsis. The sources sought requested interested parties respond to the requirement to be considered if able to provide compatible products to the Allen- Bradley MicroLogix 1400 Programmable Logic Controller (PLC) and Allen Bradley 1762 Series Input/Output (I/O) Module. By the due date, there were four responses to the sources sought notice for this requirement.

One response suggested as a possible alternative, and provided the technical data and specifications for the product. One response suggested , but only provided the cut sheet and did not indicate how the would interface with the existing system.

One response provided Statement of Qualifications to replace the system in its entirety, and one response was a supplier of the product the Government is intending to utilize. Based on the justification provided in paragraph 5, it is reasonably assumed that Allen-Bradley is the only source that can satisfy agency requirements. We consider the sam.gov synopsis as our market survey.

7. Determination of Fair and Reasonable Cost.

The Contracting Officer has determined the anticipated cost to the Government of the supplies/services covered by this J&A will be fair and reasonable.

8. Market Research.

a. Market research was conducted on 13 January 2022 to determine if there were any vendors who could provide similar items, and to perform a price comparison. As mentioned above in paragraph 6, there were four responses to the sources sought notice posted.

b. Additional market research found four other PLC and I/O manufacturer(s) other than Rockwell Automation. However, these other manufacturers PLC and I/O are not used within the existing WWTP SCADA system.

c. Out of all the PLCs, the Allen-Bradley MicroLogix 1400 Programmable Logic Controller (PLC) and Allen-Bradley 1762 Series Input/Output (I/O) Module is the only approved ATO compliant solution.

9. Actions taken to remove barriers to future competition.

To evaluate the use of full and open competition for acquiring the same or similar supplies in the future, NAVFAC Hawaii will continue to monitor the automation industry and coordinate with NAVFAC CIO for a product that could satisfy the items noted in paragraph 5. Should any other potential sources of supply become available during the source selection process, the Government will consider each as applicable.

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein are complete and accurate to the best of my knowledge and belief.