JUSTIFICATION_AND_APPROVAL_-_REDACTED.pdf

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EO 14398 - This requirement is for support service
Solicitation number
140G0326Q0138
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Brand Name Justification for Acquisition Under Simplified Acquisition Threshold

This document is a brand name justification for a single-source procurement under simplified acquisition procedures. The US Geological Survey (USGS) Acquisitions Branch, under the Department of the Interior, seeks to procure drill site supplies for groundwater observation wells at multiple Virginia Coastal Plain locations in 2026 under a firm fixed price purchase order. The specific products required are CETCO PUREGOLD® easy mixing, organic-free, high-solids bentonite grout in 50-lb bags and FILPRO sand #3 in 50-lb bags.

The justification for single-source procurement centers on requirements established by the cooperating funding agency, the Virginia Department of Environmental Quality (VA-DEQ). The VA-DEQ's operating procedures mandate the use of CETCO Pure Gold based on extensive knowledge of local aquifer systems and prior experience in areas affected by seawater intrusion. Alternative grout products from manufacturers including Wyo-Ben, Western Clay, Western Hydro, PDS Drilling Solutions, and Baroid/Halliburton have caused grout seal failures between wells at different depths and excessive equipment wear. The VA-DEQ has explicitly stated it will not approve work using any product other than CETCO Pure Gold. The contracting officer has determined that fair and reasonable pricing will be ensured through competition among resellers in the open market, and future similar requirements will be competed to the maximum extent practical.

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BRAND NAME JUSTIFICATION FOR ACQUISITION UNDER THE

SIMPLIFIED ACQUISITION THRESHOLD

PR 44047610

1. Contracting Agency and Activity. The Acquisitions Branch of the US Geological Survey, Department of the Interior, needs well construction supplies for groundwater observation wells at several Virginia Coastal Plain sites specified by the Virginia Department of Environmental Quality (VA-DEQ) in 2026.

2. Nature of Action Being Approved. Firm Fixed Price Purchase Order for USGS drill supplies (CETCO PUREGOLD® easy mixing, organic-free, high-solids bentonite grout, 50-lb bag; and FILPRO sand #3, 50-lb bag)

3. Description of Supplies or Services. Drill site supplies

4. Estimated Dollar Value.

5. Statutory Authority. This documentation is prepared in accordance with FAR/RFO Part 11, “Items Peculiar to One Manufacturer”, and RFO 12.102(a), Soliciting from a Single Source, for simplified acquisition procedures.

6. Rationale Supporting Use of Citation in No. 5. The use of CETCO Pure Gold is required because this product is specified in the operating procedures established by the cooperating agency funding the work. The cooperating agency has long-term and extensive knowledge of the local aquifer system and the construction of monitoring wells in areas where seawater intrusion has occurred or is expected to occur. Based on prior experience, the use of alternative grout products has resulted in the breakdown of grout seals between wells installed at different depths, which can render a monitoring site unusable and call into question the quality and reliability of the data collected. The cooperating agency has stated that it will not approve or sign off on work completed by the USGS using any product other than CETCO Pure Gold. Therefore, the use of CETCO Pure Gold is essential to meet the project’s technical requirements, preserve long-term well integrity, ensure data quality, and satisfy the requirements of the cooperating agency funding the work.

7. Other Information. N/A

8. The Efforts to Identify Additional Sources Including the Market Research Conducted.

Market research identified other manufacturers of bentonite grout and well-sealing products, including Wyo-Ben, Western Clay, Western Hydro, PDS Drilling Solutions, and Baroid/Halliburton. However, these products were not determined acceptable for this requirement because the cooperating agency’s operating procedures specifically require CETCO Pure Gold, and prior use of alternative grout products has resulted in grout seal failure between wells set at different depths, or excessive wear on grouting pump equipment.

Therefore, although similar products exist commercially, no acceptable substitute product was identified for this specific requirement.

9. Actions to Overcome Barriers to Competition.

Future requirements for the same/similar items will be competed to the maximum extent practical.

10. Recommendation and Certification from Program Office

Based on the information above, I recommend that this acquisition be conducted on a limited-source basis to comply with our agreement with the Virginia Department of Environmental Quality (VA-DEQ).

11. Certifications and Approval from the Contracting Officer:

a. This requirement will be solicited through the open market. As a result, the contracting officer has determined that the anticipated cost to the government will be fair and reasonable based upon competition among resellers.

b. This justification is accurate and complete to the best of my knowledge and belief.

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