JA for Under SAT signed_redacted.pdf

United States Department of Agriculture Decision to Restrict Competition under the Simplified Acquisition Threshold

Identification Number:

Rev. 10/29/25

In accordance with the Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) FAR

12.102 (a), the following documents the decision to restrict competition for this acquisition.

(1) Mission Area and Contracting Activity.

Requisition Number: 1161403 / 1232SA26Q0023

Requesting Activity Agency: USDA-ARS, SEA-Soil Dynamics Research Unit

Contracting Activity: Contracting Operations Branch, Acquisition and Property Division

(2) Brief Description of Supplies or Services

Repair of Associated Particle Imaging Neutron Generator (Model DT108-API), which has developed a gas leak due to a cracked weld on the main accelerator tube housing. It will involve replacing the viewport, scintillator crystal, and scintillator holder. Controlled disposal of defective components according to Nuclear Regulatory Commission (NRC) requirements as they will be contaminated with tritium. Examine 0.8 micron foil installed below the scintillator crystal which serves to shield the scintillator from the light of the ion beam for damage. If it is torn, remove it.

Use appropriate sealant and bake system to ensure sealant is cured appropriately. Leak test system to ensure it meets specifications for pressure and confirm neutron generation occurs. 3 month warranty on workmanship and parts. Provide return to service documentation.

(3) Suggested Source

Adelphi Technology Inc.

2003 E Bayshore RD Redwood City, California 94063

UEI: FE2HY976FJW7

(4) Justification for Restricting Competition and the Basis for that Decision.

A. Explain the unique qualifications/characteristics of the proposed contractor or product and why no other contractor or product/service can meet the Government's need.

The Adelphi/API neutron generator incorporates proprietary ion source designs, sealed deuterium/tritium tubes, HV acceleration structures, and embedded electronics that are not publicly documented. Component specifications, tolerances, and calibration data are protected IP, and only Adelphi holds:

Engineering drawings Firmware and diagnostic software Tube replacement procedures Calibration algorithms for anisotropic neutron output and associated-particle imaging

No third party has legal access to these materials.

United States Department of Agriculture Decision to Restrict Competition under the Simplified Acquisition Threshold

Identification Number:

Rev. 10/29/25

The unit uses associated-particle detection geometry, scintillator alignment, and embedded timing electronics that are:

Covered under Adelphi/Starfire/API patent families Manufactured exclusively by Adelphi OEM Not reverse-engineerable without violating export controls and IP laws

Neutron generators using tritium-loaded targets fall under:

U.S. NRC regulations Export Administration Regulations (EAR)

Only Adelphi is licensed and authorized to:

Open, reclaim, or recharge the tritium-containing sealed tubeVerify integrity of the pressure vessel Perform post-repair radiation certification

B. Describe market research conducted and the results or the reason why no market research was conducted.

Covered in 3, but we did contact two other manufacturers about repairs to neutron generators in general. This Adephli unit is a backup to a Thermo Fisher API 120 unit which also reached the end of its service life. Thermo Fisher declined to repair the unit as it is now disconinued and no longer supported. They cited an extremely difficult and delicate process to work with thin scintillator crystals and have no plan to enter into this segnment of the market again. Starfire Industries said it was unlikley they could do the work.

Certifications & Approvals

(5) Technical / Requirements Personnel Certification I certify this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

Date

(6) Contracting Officer’s Certification I certify that the data supporting the recommended use of other than full and open competition accurate and complete to the best of my knowledge and belief. I hereby approve this justification.

Date