JA Sole Source Rockwell Brand Name (Redacted).pdf

Control No.: LRE-FY21-02

Justification and Approval (J&A) for Other Than Full and Open Competition

1. Contracting Activity: U.S. Army Corps of Engineers (USACE), Detroit District, 477

Michigan Avenue, Detroit, MI 48226

2. Description of Action: Approval is requested to employ brand-name for Allen-Bradley

Remote Input/Output (I/O) equipment by Rockwell Automation in the specifications of a firm-fixed price construction contract for the rehabilitation of the ship arrestors of the Poe

Lock located at the USACE, Detroit District, Soo Area Office (SAO) in Sault Ste. Marie, Michigan. The Government will not purchase the Rockwell Automation components directly and will include the requirement in a competitive solicitation for the construction project.

The contract is funded as a Construction General Funded project using FY18 Funding and shall be solicited as an unrestricted Request for Proposal (RFP) using the Best Value Trade

Off Method (FAR 15). The contract magnitude is estimated between $10,000,000 to

$25,000,000. The value of the Rockwell Automation components is approximately $7,000.

3. Description of Supplies/Services: The project specifications include separate instances where the name brand is used to describe the project requirements. The components to be identified by brand name, Allen-Bradley, are listed below:

Quantity Description Part No.

4 each Communications Adapter 1734-AENTR

8 each Safety-Rated Digital Input Module 1734-IB8S

4 each Digital Input Module 1734-IB8

4 each Digital Output Module 1734-OB8

4 each Safety-Rated Analog Input Module 1734-IE4S

4. Authority Cited: 10 U.S.C. 2304(c)(1) as implemented by FAR 6.302-1(a)(2), only one responsible source and no other supplies or services will satisfy agency requirements. This

J&A is required in order to use the Rockwell Automation components to describe the requirements for the rehabilitation of the Soo Poe Lock ship arrestors.

5. Reason for Authority Cited: In accordance with 10 U.S.C. 2304(c)(1), FAR 6.302-1(a)(2), the only responsible source is listed, and no other sources of supply will satisfy agency requirements for applications of this procurement. In accordance with FAR 6.302-

1(c)(1)(ii)(A), this justification only covers the portion of the acquisition which is specific to one manufacturer and the approval level requirements will only apply to this portion.

The listed equipment is required to ensure standardization and interoperability with the existing safety related control system (SRCS). In order to use an alternative product, the

SAO would have to replace the existing SRCS equipment and software, which would be prohibitively expensive, especially given the relatively low cost of the equipment being procured. While some other products could possibly be made to interface with the existing system, such interfacing would not be easy and, even if made compatible, would quickly be

J&A Sole Source Rockwell Brand Name Control No.: LRE-FY21-02 rendered incompatible by Rockwell software updates. If the I/O components were to malfunction due to incompatibility, that malfunction would negatively impact the safe operation of the ship arrestors.

(a) Background:

A ship arrestor system prevents vessels from impacting the miter gates and causing damage. The system is essentially a steel cable stretched across the lock, similar to a steel cable installed on divided highways to stop veering drivers from entering the opposing lane. The difference is the equipment on the ship arrestor system is significantly upsized since it’s designed to stop a 1,000 ft vessel. The ship arrestor system is comprised of a boom that supports the wire rope. The boom raises the cable out of the way when the vessel passes and lowers the cable to protect the miter gates. The socket connects the wire rope supported by the boom to the stationary piece of wire rope on other side of the lock. Raising and lowering the 100 ft boom requires powerful machinery and there are hydraulic engines to absorb the impact, so the cable doesn’t break. The hydraulic engines require a tank of pressurized hydraulic oil. The oil must be kept warm to maintain the viscosity, so it flows during the cold weather.

The overall project is to rehabilitate the fenders since much of it is original equipment installed in 1968. This contracting action to sole-source Rockwell equipment in support of 1) monitoring and control of the temperature and pressure of the hydraulic oil; and 2) interlocking the raised boom when vessels are near to prevent it from lowering. If the boom were to lower with a vessel underneath, then it and vessel would likely be damaged and anyone in the area could be harmed. The severity ranges widely since the vessel is

1000 feet long with most pilot houses located at the rear of the vessel.

The existing fenders are controlled by an Industrial Control System (IC System) that spans all four corners of the lock. Technically, it’s a safety related control system

(SRCS). SRCS prevents hazardous energy from occurring. There are several hazards on the lock. For the fender, the hazard is lowering it as a vessel passes (as mentioned in the previous section). If this were to happen, then a Board of Review would likely convene.

The main task of the safety system designer is to prevent hazardous conditions and to prevent unexpected startup. The design was based on the Category method of the older standards given the design started in 2010. The design objective was to maximize the use of the safety technology, achieving a Category 3 or Category 4 per system. The safety classification is for the system; it’s not component based, but how the components are manufactured and integrated into the safety strategy. The components of a SRCS are significantly different as compared to a traditional PLC-based IC System. The instrumentation circuits differ since the safety electronics sends a pulse through each circuit to detect a short circuit or wire off and there are two control circuits for an input device like a limit switch. A traditional system would use a single limit switch, whereas a

SRCS uses two limit switches. Field devices, such as a limit switch or motor contactor, are designed for SRCS so contacts don’t weld, have tamper seals to block manual operation, and auxiliary contacts are physically interlocked, so they all send the same signal. Network communications involved additional safeguards since failure could result in catastrophic personal injury. The embedded safety controller performs significantly more diagnostics than a traditional controller. The point is a SRCS takes an extreme amount of time to design, commission, and maintain. Failure of equates to bodily harm, and in this case long-lead time equipment will be critically damaged

(b) Justification:

These four Point Guard I/O drops have to be Rockwell Automation products because they are being added to an existing SRCS, which is based on the Rockwell Automation

Safety Technology, and need to interface with the SRCS. The SRCS has several safety functions; the new equipment to prevent the hazard of dropping the boom onto a vessel must interface to the existing SRCS cabinets that are located in the fender and socket pump rooms. This is not a new install. These four Point Guard I/O drops are not an isolated. They have to be of the same technology as the existing SRCS to be able to interface with the SRCS.

The Government has conducted market research to determine whether other components will work with the Rockwell Automation SRCS. While that market research revealed several products that could technically interface with the SRCS, such interfacing would not occur out of the box, if at all. Rather, to possibly make the third-party products work with the existing SRCS, SAO personnel would have to expend significant effort to specifically program them. Even if personnel could make third-party products compatible with the existing system, which is not guaranteed, the compatibility would not last long. Rockwell frequently provides updates to the software for its system components. While Rockwell ensures that its own products (like Allen-Bradley) are compatible with any updates, the same is not true for third-party products. Thus, even if

SAO personnel could make a third-party product compatible with the SRCS temporarily, permanent compatibility could not be guaranteed.

(c) Alternatives: There are no acceptable alternatives to using Rockwell GuardLogix.

Introducing another manufacture into the existing control system introduces unacceptable risks to the reliability of the complex control system, cybersecurity risk, and increases the cost of maintenance and support.

(d) Impact: Supporting open competition from multiple manufacturers for Remote I/O equipment is not cost-effective and introduces unacceptable risks. The actual purchase cost between reputable manufacturers of Remote I/O equipment is comparable.

However, for every different manufacturer tens of thousands of dollars in indirect costs for support equipment, training, prolonged integration and commissioning, and spare parts are required. The existence of differences of data, patent rights, copyrights, and manufacture design and processes limits the ability to operate and maintain multiple manufacturers with one common set of support assets. Therefore, it is extremely likely that an award to any source other than Allen-Bradley for Remote I/O would result in a substantial duplication of cost to the Government that would not be recovered through competition. In addition to the extra cost, the Government also incurs extra risk of equipment malfunction, cybersecurity violations, and lowered operational reliability.

6. Efforts to Obtain Competition: As discussed below, market research including investigation to determine if other systems existed that was compatible with the existing facility’s system were conducted by the design team. Due to the technical limitations of effectively communicating between different brands of safety control architectures, no cost-effective alternative was found.

7. Actions to Increase Competition: USACE will publicize the solicitation of the construction contract in accordance with FAR Part 5. Any communications from interested providers during that time will be considered.

8. Market Research: Market research using quotes from Remote I/O distributors, study of alternative brand Remote I/O user manuals, communication with the Soo Lock complex

Regional Technical Specialist for controls engineering, and communication with the local

Rockwell Automation safety technology representative was performed. A WAGO 750 series

Remote I/O system was found that can technically integrate into the existing Ethernet/IP fieldbus. There are likely other brands that manufacture Remote I/O equipment that could also integrate into the Ethernet/IP fieldbus. However, using any brand other than Allen-

Bradley for Remote I/O equipment will incur substantially more cost to the Government and introduce unacceptable risk of communication reliability.

9. Interested Sources: Allen-Bradley Remote I/O equipment is the only known source capable of providing the service. To date, no written responses have been received.

10. Other Facts: None. All pertinent facts are stated in the paragraphs above.

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.

Signature: Date:

Walter E. Hart

Electrical Engineer LRE

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.

Darin H. White

Lead Engineer, INDC

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable based on published prices and previous use of the same components.

Sandra M. Kenzie

Contracting Officer

14. Legal Review and Concurrence: I hereby determine that the information herein is legally sufficient, and I concur with the sole source procurement.

Adam Wallace

District Counsel

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

Approval

Based on the foregoing justification, I hereby approve the procurement of the Remote I/O components on an other than full and open competition basis pursuant to the authority of 10

U.S.C.23 2304(c)(1), FAR 6.302-1, subject to the availability of funds and provided that the services and property herein described have otherwise been authorized for acquisition.