JOFOC -PHMSA-PL3275 V2.1 (004).pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

Upon the basis of the following Justification, I hereby approve, as the Contracting Officer, the solicitation of the proposed purchase order described using other than full and open competition pursuant to the authority of 41 U.S.C. 253 (c)(1).

JUSTIFICATION

1. Agency & Contracting Activity:

U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Contracts and Procurement, PHA-30.

2. Nature of Action Being Approved:

Contracting without providing for full and open competition.

3. Description of Supplies or Services:

To establish a contract in support of PHMSA’s Pipeline Safety Office of Training and Qualifications

(TQ) General Pipeline Safety Awareness Course, PHMSA PL-3275, to be conducted at Leak City in

Athens, AL.

4. Statutory Authority: 41 U.S.C. 253(c) (1), Only One Responsible Source and No Other

Supplies or Services will satisfy Agency Requirements.

5. Rationale Supporting Use of Citation in No. 4:

It has been determined that the contractor, The City of Athens Utilities and Gas Co., is uniquely qualified to address the support required and provide its training facility for the 5-day General Pipeline Safety

Awareness Course, PHMSA PL-3275. The contractor has been providing its training facility for the

PHMSA TQ course to Federal and State pipeline safety inspectors since its inception in 1994, which includes the provision of fire safety equipment to meet OSHA regulations and coordination with local fire safety officials. The training site has evolved into a model pipeline safety training facility, known as

“Leak City,” and is especially unique for the PHMSA PL-3275 course, which includes 24-hour

HAZWOPER training.

This facility was designed and constructed to provide several situations which are conducted outside that a student could encounter in the field. These facilities include:

• Firefighting simulations for students. This outdoor exercise involves natural gas facilities that have been installed below ground through pits, that are ignited and the students working with an instructor proceed to put the fire out with a fire extinguisher. This practice involves several fire pit configurations with gas entering at different locations. Additionally, a propane tank is set up for a fire impingement demonstration and the students put out the fire with fire extinguishers.

• Decontamination station. As required by OSHA regulations for the 24-hour HAZWOPER training, this outdoor exercise is where students are brought into a decontamination station. The students experience the decontamination process to understand the requirements to ensure how an individual is decontaminated after being exposed to hazardous materials.

• Confined Space Entry pit. Inspectors are often required to climb down into confined spaces in the course of their work. This outdoor exercise and facility provide the student with the knowledge of what is required on entering and exiting a confined space.

The City of Athens Utilities and Gas Co. staff support the course by:

1. Coordinating and having available fire service personnel and equipment;

2. Controlling the natural gas to the fire pits and propane tanks.

3. Contracting and having on site, Ansul fire extinguisher representative to inspect, charge and re-charge fire extinguishers as needed for Fire School afternoon and evening sessions;

4. Setting up and providing classrooms;

5. Storing, maintaining and providing fire suits and other PPE equipment as needed;

6. Maintaining and making ready confined-space entry facilities;

7. Maintaining, operating and having available telemetric facilities for simulation in central location;

8. Maintaining, operating and having available pigging facilities for simulation in central location;

9. Maintaining, operating and having available emergency response scenario facilities, including district regulator station and vehicle collision mock facilities;

10. Maintaining, operating, and having available emergency and leak response buildings to provide scenarios; and

11. Providing and having available first aid equipment and ambulance services.

6. Determination of Fair and Reasonable Anticipated Cost:

The proposed costs for the effort will be analyzed in detail by the Contracting Officer to ensure that they are realistic, fair, and reasonable. We have compared with previously provided prices and they are comparable to work performed in the past.

7. Market Research or Statement of Reason Market Research Was Not Conducted:

PHMSA/TQ has conducted market research to determine if similar facilities are available to deliver the course curriculum for the General Pipeline Safety Awareness course which includes 24 - HAZWOPER training and firefighting.

There are several natural gas companies that have built training facilities in the U.S. These include

Southwest Gas, Washington Gas Light Company, and Atmos Energy. These facilities are not an option for our class because:

• They are not for public use and are not for rent. They are only used to train their own employees.

• Only one has the firefighting facilities.

• None of them hazardous material exposure decontamination facilities.

PHMSA/TQ has not been able to find any other companies that provide the outdoor training facilities for the exercises conducted in this class.

8. Future Plans to Permit Competition:

This course is annual training offered by TQ. The first course procured through PHMSA (PHA-30) was in

October 2008. The City of Athens Utilities and Gas Co. has personnel, equipment, and a unique training facility with exclusive and extensive expertise and location in pipeline safety and OSHA safety requirements and, currently, there are no plans for competition.

TECHNICAL AND REQUIREMENTS CERTIFICATION (FAR 6.303-2 (b))

I certify that the facts and representations under my cognizance, which are included in this Justification and which form a basis for this Justification, are complete and accurate.

CONTRACTING OFFICER’s CERTIFICATION (FAR 6.303-2 (a) (12))

I certify that this Justification is accurate and complete to the best of my knowledge and belief.

Dwayne Cross

Contracting Officer

PHMSA