JOFOC_Generator_Replacement_80SSC025R0004_REDACTED.pdf

Rev.:10/2025

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

STENNIS SPACE CENTER (SSC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For SSC TORNADO RESILIENCY – GENERATOR REPLACEMENT FOR TEST

COMPLEX

1. Federal Acquisition Regulation (FAR) 6.104-1(a)(1) – Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for other than full and open competition.”

This document is a justification for other than full and open competition prepared by

National Aeronautics and Space Administration (NASA) NASA Shared Services Center

(NSSC).

The procuring agency is the NASA, and the contracting activity is the NASA Shared Services Center (NSSC).

2. FAR 6.104-1(a)(2) – The nature and/or description of the action being approved:

This justification provides the rationale for contracting by other than full and open competition to award a sole-source Task Order (TO) against GSA Areawide Public Utility Contract (GWAC) 47PA0425D0027, awarded June 12, 2025 to Mississippi Power Co (MPC), with a ten-year period of performance. Per the GWAC, “Ancillary Services means Contractor’s services which are provided to an Agency and which are routinely provided by the Contractor, including but not limited to, total maintenance and repair, major restoration and repair, operation and maintenance, studies, emergency restoration resulting from Acts of God, routine maintenance, mapping of an Agency’s facility, and government-owned line extensions, and any other services, as appropriate" (emphasis original). Accordingly, this project for major restoration and replacement of SSC’s Test Complex generators which connect to MPC’s 13.8kV high voltage system, is ancillary to the electric service already provided to Stennis Space Center (SSC) by MPC, as it falls under both restoration and "any other services, as appropriate" in the definition.

3. FAR 6.104-1(a)(3) – A description of the supplies or services required, to meet the

Agency’s needs (including the estimated value):

The contractor shall provide all required labor, material, tools, and equipment to design and implement the scope of work identified within the Statement of Work (SOW) and supporting contract documents. This project involves the major restoration and replacement of SSC’s Test Complex generators located at B-4400. The generators connect to MPC’s 13.8kV high voltage system and provide backup power to the test complex. The existing generators have been in service at SSC for the last 56 years and are currently outdated and unreliable. This project will replace the existing generators to ensure reliable emergency power restoration to the test complex during future outages. This project requires the following:

a. Replace the four (4) existing 1.5MW, 4160V generators at B-4400 with new generators of lesser capacity. Removal of the existing generators is not in scope. Existing 4160VAC transformers will remain in place.

b. New 480V generators will be capable of delivering a maximum of 3.5MW of emergency power to the test complex. Assume a generator configuration of 2x1750kW.

c. Perform load study to verify generator sizing.

d. Provide all necessary equipment including 15kV breaker, 480V step-up transformers transformer, NEMA 3R Low Voltage switchgear/equipment, relays, etc., to connect the new generators to the HV switchyard.

e. Provide generators with day-tank. Connect to the existing B-4400 diesel storage tanks.

Provide new piping and transfer pumps to the generators. Provide elevated metal platforms for generator maintenance/access.

f. Provide provisions to connect a spare/portable generator.

g. Connect the new generators to site Emergency Management and Control System (EMCS) and to B-4400 Control room for monitoring.

h. New generators will have the capability to synchronize with the utility power grid.

i. The new generators are to be used as emergency backup only.

j. Replace existing knife-blade switches on Circuits 11 and 21, feeding the underground circuits on the north side of the B-4400 switchyard with new Gang-Operated Air Break (GOAB) switches.

k. Replace sand fuses feeding B-4400 480VAC transformers 400A and 400B with modern fuses.

The estimated time of completion for this work is 30 months and the estimated cost is

4. FAR 6.104-1(a)(4) – An identification of the statutory authority permitting other than full and open competition:

The statutory authority permitting other than full and open competition is 10 U.S.C.

3204(a)(1), as implemented by FAR 6.103-1 Only one responsible source and no other supplies or services will satisfy agency requirements.

5. FAR 6.104-1(a)(5) – A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited:

The rationale supporting the use of 10 U.S.C. 3204(a)(1) is that MPC is the only entity with legal authority and technical control over its distribution system to which these generators will interface and is the sole source capable of meeting NASA’s requirements for secure and reliable integration of the generators to the distribution system as described below (See Mississippi Public Service Commission’s Distributed Generation Rules, Mississippi Power Distribution Generator Interconnection Procedures, and Southern Company Operation of Distribution Generator Interconnection Procedure in Parallel with the Distribution System Policy).

These generators are part of Mississippi Power’s, Public Service Commission (PSC) approved Standby Generator Program in which NASA has participated for over two decades.

This program, which is an important aspect of NASA’s overall energy resilience, and which provides significant utility bill credit to NASA, allows MPC to dispatch the generators during capacity needs which requires that the generators be integrated with MPC’s system, so that they can parallel and export to the utility power grid.

This project involves the interconnection of new generators with an estimated capacity of 3.5MW at B-4400. The new generators will be used to provide emergency power to the A/B test complex through the local 13.8kV distribution system. Although the new generators will be physically located at B-4400, they will be electrically connected to the MPC utility grid enabling synchronization. This interconnection is necessary to allow seamless operation and transfer of load between the generators and utility power. Additionally, under the standby agreement approved by the Mississippi PSC, these generators are intended not only for backup power but also for potential export of electricity to the grid during peak demand or emergency conditions. The generators need to be bespoke to be compatible with the MPC distribution system. As the operator of the system into which the generators will connect, MPC is the sole entity with both the system knowledge and capability to meet NASA’s requirements for designing, installing and interconnecting a complete generator system that securely integrates with the distribution system. MPC’s comprehensive purview of the system, including the generator component of that system, is necessary to guarantee the security and energy resilience for the test complex. Per utility regulations and industry practice, MPC retains exclusive responsibility for grid-facing work within its operational footprint. No third-party contractor may perform, alter, or commission work that directly interfaces with the utility’s protection schemes or substation assets without MPC engineering review, approval, and direct oversight.

The scope of this work includes highly specialized engineering, system protection coordination, interconnection studies, and operational oversight. MPC possesses proprietary knowledge and operational jurisdiction over protection settings, coordination protocols, and substation controls that are critical to the safe and compliant interconnection of the new emergency generation assets. Because of this, no other entity can perform this work under the utility regulations.

To ensure compliance with regulatory requirements, maintain grid reliability, enhance security, and mitigate liability risk, Mississippi Power Company must be the sole entity responsible for the design, installation, and interconnection of any generators that interconnect with and provide power to the utility power grid.

6. FAR 6.104-1(a)(6) – A description of the efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by Part 5 and, if not, which exception under part 5 applies:

A notice to the Government Point of Entry (GPE) website (Sam.gov) was published on August 8, 2025, in accordance with FAR Subpart 5.2. This posting informed potential sources of NASA’s intent to award this sole-source Task Order to Mississippi Power Co.

The results of this synopsis are summarized in Section 10 below.

7. FAR 6.104-1(a)(7) – A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable:

The Contracting Officer’s signature on this document indicates that the Contracting Officer has determined that the anticipated cost to the government will be fair and reasonable. The Contractor must be required to submit a proposal to be evaluated and negotiated by the Government. Prior to execution of the contractual instrument, a proposal analysis will be performed. The proposal analysis will ensure that the final agreed-to price for the contract action is fair and reasonable, in accordance with FAR Part 15. Specifically, the CO will require certified cost or pricing data and will compare that data to the Government estimate.

Should there be any major discrepancies in cost elements, the government will request the offeror to submit cost information concerning that element. Additionally, proposed pricing may be compared to other similar types of work as well as the material components compared to the costs of equivalent, commercially available items.

8. FAR 6.104-1(a)(8) – Description of the market research conducted, and the results, or a statement of the reasons market research was not conducted (e.g., urgent, and compelling requirement):

A considerable about of market research was performed by the CO to determine if this project was truly sole source. A simple internet search will prove that ample businesses are capable of generator replacement and installation. However, this scope of work is much more complicated than a simple generator replacement and installation as it requires the necessity to connect to and work in parallel with the local Electric Distribution System (EDS).

Therefore, market research efforts were focused specifically on the requirements associated with interconnecting to the EDS which is owned and controlled by MPC. Sources included:

• www.mississippipower.com

• Mississippi Public Service Commission’s Distributed Generation Rules

• Mississippi Power Distribution Generator Interconnection Procedures

• Southern Company Operation of Distribution Generator Interconnection Procedure in

Parallel with the Distribution System Policy

• Mississippi Power Company’s Rules Governing Electric Service

After thorough review, it was determined that while third party entities may possess the qualifications necessary for individual components of the scope of work, there is no entity capable of performing the complete scope of work, other than MPC, since they are the sole manager of all parallel interconnections to the EDS.

Additionally, there is a current GSA Areawide Public Utility Contract with MPC for Electric Service, Steam Service, Energy Management Service and/or Services Provided Under the Appropriate Regulatory Authority. This area wide contract is available for use by SSC to procure the entire scope of work required for this project as an ancillary service per

EXHIBIT “A” MISSISSIPPI POWER COMPANY, AUTHORIZATION FOR ELECTRIC

SERVICE, CHANGE IN ELECTRIC SERVICE, OR DISCONNECTION AND/OR

TERMINATION OF ELECTRIC SERVICE UNDER, AREAWIDE CONTRACT NO.

47PA0425D0027.

9. FAR 6.104-1(a)(9) – Any other facts supporting the use of other than full and open competition:

None.

10. FAR 6.104-1(a)(10) – A listing of the sources, if any, that expressed an interest in writing in the acquisition:

A notice of NASA’s intent to award this sole-source action was synopsized on the GPE website (Sam.gov) per FAR Subpart 5.2 (See Section 6 above). Two companies submitted their written interest via email to the CO.

The first response was received from Pacific Northwest Power on Monday, August 11, 2025.

Their interest was specific to the existing generators on site being replaced. Per their email, they buy used generators and electrical distribution equipment. They did not submit any interest in the actual scope of work for the project. Additionally, they did not submit their capabilities and/or qualifications to complete the effort, per the instructions of the special notice.

The second response was received on August 18, 2025 from Flying V Rentals. Their email expressed interest in bidding on, “any generator work,” and stated that they, “supply and install almost every kind of backup generator.” Per the special notice posted to SAM.gov, interested organizations were advised to send their capabilities and qualifications to perform the effort described in the notice to the CO for consideration. Additionally, the special notice advised that such capabilities/qualifications would be evaluated solely of the purpose of determining whether to conduct the acquisition on a competitive basis. The CO conducted basic market research on Flying V Rentals. According to their website, https://www.flyingvrentals.com/, Flying V Rentals, based in College Station, TX, has been a trusted provider of power generators and equipment rentals since 2013, specializing in serving the oil and gas industry with over 20 years of combined team experience. They also offer a wide range of industrial equipment backed by 24/7 support and a proactive service approach. Their website also included a section for generators, complete with a list of offerings. The largest generator offered, per their website, had a 250kW capacity. However, the generator requirements for this effort require 1750 kW of capacity. Therefore, Flying V Rentals’ basic capability/qualification statements, coupled with market research findings, were not sufficient for the CO to make a determination that they were capable or qualified for this effort.

11. FAR 6.104-1(a)(11) – A statement of actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required:

The Agency will continue to examine the market in the future for alternative solutions or new sources before executing any subsequent acquisitions for the same requirements.

Attachments:

Statement Of Work (Tornado Resiliency – Gen Replacement SOW R01) GWAC (47PA0425D0027 Mississippi Power AWC)