JOFOC.pdf

LIMITED SOURCES JUSTIFICATION (LSJ)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

Version Control Date: October 7, 2015

Date: 02/21/2023

MEMORANDUM TO: Jerry Purcell, ADM/AMD/OBA

FROM: Kelly Dickerson, COR, RES/DRA/HFRB

SUBJECT:

☐ LIMITED SOURCES JUSTIFICATION (LSJ)

☒ JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

REFERENCE: MAINTENANCE, SUPPORT, AND ENHANCEMENTS FOR THE

NRC-OWNED GENERIC PRESSURIZED WATER REACTOR

(GPWR) SIMULATORS.

“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 objective of this contract is to (1) obtain contractor product (hardware and software) and engineering support to assist the NRC’s Human Performance Test Facility (HPTF) in upgrading and maintaining their Generic Pressurized Water Reactor (GPWR) simulators, and (2) procure simulation engineering support to aid in the development of scenarios and other materials to be used in laboratory human factors research.

b. Project background.

The NRC uses GSE Performance Solutions proprietary software and hardware in the HPTF. The HPTF was established in 2012 as a response to the commission requirement SECY-08-0195, requiring agency staff to begin conducting in-house human factors research. The proprietary hardware and software provided by GSE form the lightweight simulator-based solution used to fulfill the human performance testing requirement.

The HPTF staff have used GSE’s proprietary solution for the last 10 years (under two separate 5 year contracts) since the establishment of the facility. Other experimental software have been developed during that 10 year period and those software tools were designed to specifically integrate with GSE’s GPWR.

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

GSE Performance Solutions, Inc.

1332 Londontown Blvd., Suite 200 Sykesville, MD 21784

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

a. Project title. Maintenance, Support, and Enhancements for the NRC-owned

Generic Pressurized Water Reactor (GPWR) Simulators.

b. Project description. The HPTF simulators have been maintained on the same hardware for the last decade. The purpose of the follow-on contract is to replace all existing hardware at both HPTF sites to ensure continued operation of the facility to meet the regulatory mission defined in SRM SECY- 08-0195 and continue to support our users in the office of Nuclear Reactor Regulation (NRR). Along with a full hardware refresh, the contract requirements will include maintenance, engineering services, customer support. and continue the support agreement for the software with GSE Performance Solutions, Inc.

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): New Award for Existing Requirement

• 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-23-0096

• Total estimated dollar value and performance/delivery period. $447,509;

Base period: 04/17/2023 to 04/16/2024, plus 4 one-year option periods.

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- __.

☒ 6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements ☐ 6.302-2 Unusual and compelling urgency ☐ 6.302-3 Industrial mobilization; engineering, developmental, or research capability; or expert services ☐ 6.302-4 International agreement

☐ 6.302-5 Authorized or required by statute ☐ 6.302-6 National security ☐ 6.302-7 Public interest

☐ 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 proposed contractor, GSE Performance Solutions, Inc. is the manufacturer and distributor for several of the software applications and hardware installed on the HPTF simulators. The software applications are proprietary, and the source code is maintained by the contractor. The contractor does not authorize other vendors to maintain their installed products and integrate new 3rd party capabilities with their installed products.

The NRC has already invested in the GPWR software as well as training for the simulator users. A new simulator solution would require significant investment in both new software and significantly more expensive hardware. Changing to a new solution would also have negative consequences in terms of prolonged facility downtime while staff train on the new solution. Additionally, other simulators are designed to support only training and not both training and research use cases. The NRC requires both training and research capabilities.

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.

This acquisition will be posted on the Government point of entry (GPE) Federal Business Opportunities (FEDBIZOPS) in accordance with FAR subpart 5.2.

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.

The Contracting Officer will perform price analysis and will only award a contract if the price is deemed to be fair and reasonable. The Contracting Officer will use price analysis techniques such as a comparison of quoted prices with the Independent Government Cost Estimate, comparison with prices previously paid for the hardware, software and services, and a request that the quote also include a breakdown of the firm-fixed-price.

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.

The GSE products installed in the HPTF are closed source and proprietary. The contractor (GSE) is the developer and an expert on how to maintain and use these products for research purposes most effectively. Additionally, updates, replacements, and enhancements to the existing HPTF hardware and software systems can only be provided by this contractor.

The market research was performed by following the Market Research Checklist Guidance provided in Table 1:

The three primary methods used were (1) personal knowledge of the product space, (2) consultations with other NRC staff who use a comparable system and are familiar with the market landscape for this product and (3) an internet search for research simulators and a refined internet search for nuclear control room research simulators. Table 1 summaries the market research findings. The GPWR has the exact specifications required for the needs of the NRC without costly and time-consuming upgrades and/or customizations, which would be required if any other vendor was selected.

Table 1. Summary of Market research

Business Name Address Phone #

Email

Size of Business and NAICS Code

Small Business

Ownership Type

Organization al Conflict of

Interest (Yes/No)

Company demonstrated required capabilities provided by the NRC, if applicable?

(Yes/No; please explain)

Company demonstrated potential capability?

(Yes/No; please explain)

GSE Solutions

Small, 333310

NO YES. GSE has been the vendor for the existing simulator for the last 10 years.

They set up the system and have been servicing that system through a maintenance contract. Over 10 years of service the vendor has developed an in depth understanding of how we use their product and the

8. Other factors supporting the justification, if any.

None

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

Not applicable

Business Name Address Phone #

Email

Size of Business and NAICS Code

Small Business

Ownership Type

Organization al Conflict of

Interest (Yes/No)

Company demonstrated required capabilities provided by the NRC, if applicable?

(Yes/No; please explain)

Company demonstrated potential capability?

(Yes/No; please explain) specific unique research use case for the NRC.

Corys

Other than small business, 333310

N/A Possibly yes.

This company is owned Framatome, which is a French nuclear power company.

While we do not regulate this company, it may give the appearance of

OCIO.

No. Corys appears to specialize in training simulators. They also have some specialization in severe accident analysis. Their website does not mention research as one of their simulator solution use cases.

Yes. Their website lists simulator enhancements and upgrades as one of their core services.

However, in consulting with the TTC engineers we were advised that using a new vendor for upgrades would likely be costly and difficult.

Western Services

333310 NO No. Western Services specializes in training and their customization options appear focused on evaluating training and integrating with customers learning management systems.

No. Their upgrading support is focused on getting plants up to NRC standards and on developing training solutions.

This company’s offerings are not aligned with NRC’s needs for a research simulator.

L3 Harris

Other than small business, 333310

N/A NO No. L3 Harris appears to only develop and supply flight simulators. Their other capabilities are focused on defense and command and control.

No. They do not appear to have any nuclear domain expertise in their simulation or other offerings.

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.

AMD will closely scrutinize future requests for the renewal of GSE software and hardware and will ensure that any restrictions to competition are adequately supported and documented.

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

Kelly Dickerson Date

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

Domonique Malone Date