JA Brand Name Only M6740024Q0003_Redacted.pdf

J&A No. M62613-FY24-SSBN-02

U N I T E D S T A T E S M A R I N E C O R P S

MARINE CORPS AIR STATION IWAKUNI JAPAN

CONTRACTING DEPARTMENT

PSC 561 BOX 1872

FPO AP 96310-0019 IN REPLY REFER TO

4K

26 July 2024

JUSTIFICATION AND APPROVAL (J&A)

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

J&A No. M62613-FY24-SSBN-02

1. Agency and Contracting Activity.

Agency Contracting Activity Boiler Branch, Contracting Department Utilities Division Regional Contracting Office Facilities Department Marine Corps Air Station Iwakuni, Japan PSC Box 1871 PSC 561 Box 1872

FPO, AP 96310-0019 FPO, AP 96310-0019

2. Description of the Action Being Approved.

Request approval to use other than full and open competition to award a Firm-Fixed Price contract for NAME BRAND ONLY boiler chemicals to support the operation of boilers maintained by Boiler Branch, Utilities Division, Facilities Department aboard Marine Corps Air Station (MCAS) Iwakuni.

Boiler chemicals are essential for proper operation and maintenance of MCAS Iwakuni’s steam system. The boiler chemicals listed in Section 3 are required to prevent and eliminate hardening of iron, silica, and various other corrosives from being distributed through steam pipes and boilers. These chemicals are also required to control boiler water with adjustment of p.H.

(Hydrogen Exponent).

3. Description of the Supplies/Services.

This contract pertains to acquiring specific brand name chemicals and services required to maintain operational capabilities of MCAS Iwakuni’s steam system. Without essential chemicals to operate 4 boiler plants, the boilers and associated distribution equipment will experience advanced corrosion leading to shortened lifecycle and increased capital costs.

Estimated Dollar Value

Operation and Maintenance, Marine Corps

Name Brand Chemicals Cleansurf-S753IW2 Cleansurf D-988 Cleansurf C-359 Total

4. Statutory Authority Permitting Other Than Full and Open Competition.

This document meets the regulatory requirement at DFARS 206.302-1(c)(2) to execute the justification and approval addressed at FAR 6.303 to use brand name descriptions.

5. Rationale Justifying Use of Cited Statutory Authority.

An “OR EQUAL” chemical would not be as efficient and/or effective cleaner as our requested chemicals because the contents of the requested chemicals are proprietary and we have not yet identified an effective substitute for it.

The below listed products are proven to be effective in preventing and eliminating hardening of iron, silica, and various other corrosives from being distributed through steam pipes and boilers.

Use of the requested brand name products will prevent unnecessary expenses to the Government in emergency repairs and equipment replacements. The boilers at MCAS Iwakuni have been cyclically operated by season or by specific times during the day, and not continuously throughout the year. Therefore, because of this type of operation, corrosion in steam distribution pipes cannot be avoided and higher concentrations of oxidized iron (along with other “hardness” elements such as calcium, silica, and magnesium) in boiler feed water or condensate occur regularly. When the pH of the feed water in the boiler gets too high, the oxidized iron and hardness elements turn to scale and some end up on the interior walls of the boiler, which reduces the efficiency of boiler. To mitigate corrosion and the formation of scale, boiler feed water chemicals are carefully selected and used consistently. If the chemicals are changed (for example, from phosphoric acid to polymer), all boiler water in the boilers and station-wide piping would need to be drained, all chemical injection equipment would have to be recalibrated for the new chemical and checked for compatibility with the new chemicals, and new water with the new chemicals introduced into the complete steam system. Additionally, the method of chemical analysis would have to be changed.

Product: CLEANSURF S-753IW2 [Manufacturer: Hakuto Kagaku Co. Ltd.]

- Boiler feed water treatment for scale control and pH adjustment.

- Prevent hardness (calcium, silica, magnesium) scale and iron scale formation.

- Ingredients comply with F.D.A. (U.S. Food and Drug Administration), Section 173.310.

- Use of phosphoric acid or similar chemical is not permitted. Polymer treatment is acceptable and preferred.

- Polymer Composition: Carboxylic Acid Copolymer, Sodium Hydroxide (1-5%), Water

Product: CLEANSURF D-988 [Manufacturer: Hakuto Kagaku Co. Ltd.]

- Boiler feed water treatment for oxygen scavenging.

- Prevent pitting-type corrosion of iron.

- Efficiently and effectively deoxidize the boiler feed water.

- Ingredients comply with F.D.A. (U.S. Food & Drug Administration) regulations.

- Use of only sodium sulfite is not acceptable.

- Use of hydrazine is not permitted.

- Use of ammonium sulfite (neutral type) is not acceptable.

- Compositions: Sodium Sulfite, Potassium Hydrosulfite, Water

Product: CLEANSURF C-359 [Manufacturer: Hakuto Kagaku Co. Ltd.]

- Boiler feed water treatment for condensate corrosion control.

- Prevent corrosion in the condensate return piping.

- The chemical compound shall be volatile amine.

- The chemical is F.D.A. (U.S. Food & Drug Administration) approved for use in steam that may come in contact with humans or food.

- Prevent corrosion of copper.

- Compositions: N-Dielhyl Ethanol Amine 40%, Water Sodium Hydroxide NAOH 48% 20kg

The chemical listed above have been used in the boiler systems for decades and have consistently met the requirements.

The impact of replacing the required chemicals with different brands include the following:

a. The use of different chemicals can introduce unnecessary risk and require additional resources. It can also lead to an increased risk of cumulated iron in the feed water. To mitigate such occurrences, a significant amount of water must be intentionally wasted from a boiler to prevent the concentration of impurities during the continuous evaporation of steam. This process, known as ‘blow’, is a necessary precaution to avoid potential risks.

b. In addition, the use of different brands of chemicals would require all existing boiler water to be replaced to avoid disruption of boiler operation caused by the mixture of chemicals; the boiler operations would have to be stopped for boiler water replacement.

c. Lastly, the use of different brands of chemicals would require adjustment of quantity and render the existing chemical feed pumps unusable because of different types of chemicals or their properties. Fluctuation in supply ordering and equipment replacements creates additional costs that are not likely to be recovered through competition.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.

Previous Requests For Proposals from other vendors to fulfill this requirement returned no bids other than of the current contractor’s. MCAS Iwakuni’s remote location hinders the likelihood of more bidders for the contract.

7. Determination of Fair and Reasonable Cost.

The Contracting Officer will determine that the price for this acquisition is fair and reasonable in accordance with FAR 13.106-2 and 13.106-3, and, to the extent deemed necessary by the Contracting Officer, using price analysis technique in FAR 15.404-1 (a) and (b).

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein are complete and accurate to the best of my knowledge and belief.

Technical Cognizance:

Date

LEGAL SUFFICIENCY REVIEW

I have determined that this Justification is legally sufficient.

Signature Name (Printed) Phone No. Date

CONTRACTING OFFICER CERTIFICATION

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

August 5, 2024

August 5, 2024

N/A - MAPP, 1.602-1-100 Legal Review

August 06, 2024