LASER ABLATION JA_Final_AFC SIGNED.pdf

CUI//SP-PROCURE//FED CON

Control Number: CCAM-J&A24-1751

CUI//SP-PROCURE//FED CON

JUSTIFICATION REVIEW DOCUMENT

FAR SUBPART 13.5 SIMPLIFIED PROCEDURES

FOR CERTAIN COMMERCIAL ITEMS

SOLE SOURCE JUSTIFICATION AND APPROVAL

Program/Equipment: In support of the missions at Letterkenny Army Depot (LEAD), LEAD requires the procurement of one (1) each Laser Photonics CleanTech HH MLRI- 2000 laser ablation system with accessories, dehumidifier/air dryer unit, safety curtains, and spare parts.

Authority: The acquisition will be made under the authority permitting simplified acquisition procedures of 41 U.S.C 1901, as implemented by FAR 13.5, Simplified Procedures for Certain Commercial Products and Commercial Services, and brand name descriptions.

Amount: The total price of this requirement is $780,000.00.

Prepared by:

Typed Name: ______John W. Mason____________ DSN: __570-9666__

Title: ______Electronics Technician_____________ Date: __11 Dec 2023__

E-mail: john.w.mason2.civ@army.mil

Contracting Officer:

Typed Name: ______Thomas C. Hall____________ DSN: __570-5583__

Date Reviewed: ____22 Jan 2024____ E-Mail: thomas.c.hall111.civ@army.mil

Technical Representative:

Typed Name: ______John W. Mason____________ DSN: __570-9666__

Title: ____Electronics Technician_____ Date Reviewed: __11 Dec 2023__

Controlled by: ARMY Controlled by: ACC-RSA CCAM-DSL CUI Category: General Procurement and Acquisition Limited Dissemination Control: FEDCON POC: Thomas C. Hall, 717-267-5583

CUI//SP-PROCURE//FED CON

Requirements Representative:

Typed Name: ______Scott D. Hammond II_______ DSN: __570-5268__

Title: _____Mechanical Engineer_____ Date Reviewed: __11 Dec 2023__

CUI//SP-PROCURE//FED CON

Reviews

I have reviewed this justification and find it adequate to support other than full and open competition.

Legal Counsel

Typed Name: _______Andy K. Hughes__________ DSN: __746-0533__

Signature: _________________________________ Date: _____________

CUI//SP-PROCURE//FED CON

JUSTIFICATION AND APPROVAL

FAR SUBPART 13.5 SIMPLIFIED PROCEDURES

FOR CERTAIN COMMERCIAL ITEMS

SOLE SOURCE JUSTIFICATION AND APPROVAL

1. Contracting Activity: U.S. Army Contracting Command-Redstone, CCAM-DSL, One Overcash Avenue Building 2 South, Chambersburg, PA 17201-4150.

2. Description of Action: Letterkenny Army Depot (LEAD) requests approval to award a new Firm Fixed Priced (FFP) contract on a sole source basis with Laser Photonics, a small business located at 1101 N Keller RD Suite G, Orlando, Florida 32810-5917, CAGE 7EBG2, UEI C1TLM1LG6NE5. The Government projects award for this action in May 2024. Capital Improvement Project (CIP) funds will be used on this procurement.

An acquisition plan is not required because this procurement does not meet the threshold at Defense Federal Acquisition Regulation Supplement (DFARS) 207.103(d).

3. Description of Supplies/Services: This requirement is for the purchase of one (1) Laser Photonics portable CleanTech HH MLRI-2000 laser ablation system with accessories, dehumidifier/air dryer unit, safety curtains, and spare parts. Capital Improvement Project (CIP) funds will be used on this procurement. The total value of the requirement is $780,000.

4. Authority Cited: The acquisition will be made under the authority permitting simplified acquisition procedures of 41 U.S.C 1901, as implemented by FAR 13.5, Simplified Procedures for Certain Commercial Products and Commercial Services, and brand name descriptions.

5. Reason for Authority Cited: Procurement by other than full and open competition is necessary because the CleanTech HH MLRI-2000 laser ablation system sold by Laser Photonics is the only 2000W unit that meets the portability, variable power range, and maximum power output requirements necessary for LEADs mission. Letterkenny Army Depot requires a laser ablation system designed for use on TDY missions as part of a corrosion mitigation system. All equipment for this effort will be loaded into a Container, Express (CONEX) and sent to location where a team from LEAD will assess corrosion damage, remove the corrosion from a variety of different military assets, and then treat and repair the damaged area. LEAD requires a laser ablation system that is small and portable to be able to fit in the CONEX box for transportation to TDY locations and able to be moved to an assets location by hand if necessary. The laser ablation system must be capable of being used at various power levels because there will be a wide variety of materials and corrosion conditions encountered during TDY asset repair missions.

Substrates of varying thicknesses and different materials will require different laser ablation power settings. Lower power settings will be necessary to safely remove light surface corrosion from thin and fragile substrates, while thick and robust substrates will require the high power (2000W) setting to remove heavy corrosion. This variable power machine will allow the appropriate power level of laser ablation to be applied as needed by a trained operator. Lastly, the unit must have a maximum working power output of 2000W because the TDY mitigation team must be able to handle the removal of heavy corrosion from any surface that they encounter. LEAD currently has a 1000W laser ablation system that does not have the capability to remove heavy corrosion, but only surface corrosion. LEAD deals with heavy corrosion, such as pitting, more so than surface corrosion. Additionally, the current system does not have the ability to remove Chemical Agent Resistant Coating (CARC) paint because of the overall applied application thickness and the adhesion to the base material. The 2000W laser ablation system is required for the removal of heavy paint and corrosion from highly reflective materials such as aluminum and titanium. The high wattage is also required for stripping adhesives, epoxies, and sealants from metals due to their absorption of light and ability to adhere to the substrate. A system lower than 2000W would not be able to handle the mission of being able to remove heavy corrosion and heavy coatings from any material that the deployable unit may encounter.

Laser Photonics is the only source providing the entire package of equipment required to fulfill the laser ablation cleaning needs for LEAD. Therefore, it is necessary to request a sole source contract with Laser Photonics, CAGE 7EBG2, UEI C1TLM1LG6NE5.

6. Efforts to Obtain Competition: Market Research shows there are no other supplies that can meet the requirement. The Contracting Officer shall publish the notices required by FAR 5.2 and any bids or proposals received shall be considered. A Sources Sought was posted to www.sam.gov on 22 November 2023 for sixteen (16) days resulting in zero (0) responses. As this is a sole source action, effective competition is not applicable and will not be pursued for the reasons stated above in Section 5;

however, all responses to the posting will be considered.

7. Actions to Increase Competition: No effective competition is anticipated by LEAD to increase competition because of the proprietary status and the unique technical requirements necessary to manufacture this system. Competition is not feasible due to the specific requirements necessary for mission success. No other manufacturer can meet all the requirements. If similar efforts arise, every effort will be made to compete the requirement to the maximum extent practicable.

8. Market Research: In accordance with FAR Part 10, market research was conducted to identify potential vendors and equipment capable to support the Government’s requirement. Market research was conducted by Jody Manges, Mechanical Engineer, John Mason, Electronics Technician, Michael Gallo, Mechanical Engineer, and Jeffery Barnhart, Program manager of Product Support. LEAD currently has a 900W laser ablation unit in operation at the depot. Due to the first-hand knowledge of the capabilities of a 900W unit, LEAD determined the TDY corrosion mitigation team was going to need a 2000W laser ablation system to be able to handle the toughest corrosion mitigation tasks that the unit may face. The equipment must fit into a military shipment CONEX, be man-portable on site and provide variable power levels to treat different corrosion and base metal. Michael Gallo, Mechanical Engineer, Office of

Strategic Management, performed thorough market research of laser ablation manufacturers. As stated in paragraph 6 above, zero interest was received in response to the Sources Sought. Therefore, using the criteria previously discussed, LEAD contacted representatives of the following companies about a 2000W laser ablation unit to see if they were able to provide the type of unit that LEAD was looking for:

- P-Laser. The QF-2000 offered by P-Laser is large and bulky with trailer hitch and forklift options for portability. The QF-2000 also has a fixed power output of 1700W that could damage thin base materials during operation.

- Adapt Laser. The CL-2000 offered by Adapt Laser is not a portable unit intended for TDY applications. It is big and bulky compared to the unit from Laser Photonics, and it has a fixed power output of 1700W.

- Laser Photonics. The CleanTech HH MLRI-2000 offered by Laser Photonics is laser ablation system that is portable for TDY use and half the physical size of other units with the same power and has the advantage of having an adjustable power output of 200 to 2000 watts which other units lack.

Therefore, through the research conducted, the CleanTech HH MLRI-2000 laser ablation system is the only unit that meets all the criteria deemed necessary for the corrosion mitigation team to be able to adequately perform its TDY function.

9. Interested Sources: To date, no other sources have written to express interest in the acquisition. The notices required by FAR 5.201 shall be or have been published, and any bids or proposals received shall be considered. The synopsis for this requirement will be published in SAM on or about 20 March 2024.

10. Other Facts:

a. Procurement history. There is no procurement history.

b. Other facts. There are no other facts to justify limiting competition that were not previously stated.

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: _____________________

Typed Name: ______John W. Mason_______ Title: __Electronics Technician__

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.

Typed Name: ____Scott D Hammond II_____ Title: __Mechanical Engineer___

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. The determination will be made based upon price analysis and the Independent Government Estimate (IGE). Due to the dollar value and commercial nature of the system, certified cost or pricing data is not required per FAR 15.403.

Typed Name: _____Thomas C. Hall________ Title: __Contracting Officer_____

14. Contracting Officer Certification:

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

Typed Name: ______Thomas C. Hall________ Title: __Contracting Officer_____

Approval

Based on the foregoing justification, I hereby approve the procurement of one (1) Laser Photonics portable CleanTech HH MLRI-2000 laser ablation system with accessories and spare parts for $780,000.00 on an other than full and open competition basis pursuant to the authority of 41 U.S.C. 1901 as implemented by Federal Acquisition Regulation (FAR) 13.501(a)(1)(ii), sole source (including brand name) under the authority of the simplified procedures for certain commercial products/services, subject to availability of funds, and provided that the services or property herein described have otherwise been authorized for acquisition.

Date: _______________ Signature: ________________________

VIRGINA A. ROSACIA

Command Advocate for Competition