JA ML2650 25R2639 P222 ILDFA Redacted.pdf
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- Attached to
- N4008525R2639 DESIGN-BID-BUILD P-222: MQ-25 AIRCRAFT LAYDOWN FACILITIES, NAVAL STATION NORFOLK, NORFOLK, VA
- Solicitation number
- N4008525R2639
About this file
This is a Justification and Approval (J&A) document authorizing use of other than full and open competition for a federal construction contract.
Naval Facilities Engineering Systems Command, Mid-Atlantic is procuring Ignitable Liquid Drainage Floor Assemblies (ILDFA) manufactured by Safespill Systems LLC as part of Solicitation N4008525R2639, a Design-Bid-Build project for MQ-25 Aircraft Laydown Facilities at Naval Station Norfolk, Virginia. The project involves constructing a two-story annex to support the existing Building LP48 high bay hangar facility, including maintenance shops, secured storage spaces, Unmanned Carrier Aviation Mission Control System spaces, Weapons Training Unit operational trainer, Aerial Refueling Storage Workcenter with overhead bridge crane, telecommunications rooms with RF shielding, and personnel support areas. The estimated total project value is not fully disclosed in the document, with an unspecified portion allocated for ILDFA. Work must be completed within 1,017 days after contract award. The project is funded with FY24 Military Construction (MILCON) funds.
The J&A justifies non-competitive procurement under 10 U.S.C. 3204(a)(1) based on the determination that only Safespill Systems LLC can provide ILDFA technology meeting Navy requirements. ILDFA is presented as the only viable alternative to Aqueous Film Forming Foam (AFFF) systems, which were prohibited after October 1, 2024 under the National Defense Authorization Act for Fiscal Year 2020. ILDFA uses passive containment to manage flammable liquid spills without toxic chemicals, requires less water infrastructure, and produces zero environmental impact. A sources sought notice published March 16, 2026 on SAM.gov with a response deadline of March 31, 2026 yielded no alternative sources. The Contracting Officer will determine fair and reasonable pricing through comparison of proposed prices with the Independent Government Cost Estimate, historical data, or market survey results prior to award. The solicitation notice will be published on SAM.gov in accordance with applicable regulations.
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Text version
DEPARTMENT OF THE NAVY
NAVAL FACILITIES ENGINEERING SYSTEMS COMMAND, MID-ATLANTIC
9324 VIRGINIA AVENUE
NORFOLK VIRGINIA 23511-3095
J&A No. ML-26-50
CON/363
JUSTIFICATION AND APPROVAL
FOR USE OF OTHER THAN FULL AND OPEN COMPETITION
1. Contracting Activity.
The contracting activity is Naval Facilities Engineering Systems Command, Mid-Atlantic (NAVFAC
MIDLANT)
2. Description of the Action Being Approved.
This Justification and Approval (J&A) authorizes the use of brand name specifications for Ignitable Liquid Drainage Floor Assemblies (ILDFA) manufactured by Safespill Systems LLC in Solicitation N4008525R2639, Design-Bid-Build P222 MQ-25 Aircraft Laydown Facilities, Naval Station Norfolk, Norfolk, Virginia.
3. Description of Supplies/Services.
The intent of solicitation N4008525R2639 Design-Bid-Build, P-222, MQ-25 Aircraft Laydown Facilities Naval Station Norfolk, Norfolk, Virginia is to construct a two-story annex to support existing high bay hangar facility, Building LP48. Annex will consist of 01 and 02 spaces constructed of reinforced concrete masonry unit (CMU) walls and a combination of masonry and metal panel veneer. Annex spaces will include maintenance shops, secured storage spaces, Unmanned Carrier Aviation Mission Control System (UMCS) spaces, Weapons Training Unit (WTU) operational trainer and applied instruction space, Aerial Refueling Storage (ARS) Workcenter with overhead bridge crane, mission equipment support areas and other equipment rooms and personnel support areas. Telecommunications rooms and secure areas will meet ICD 705 requirements and have various levels of RF shielding.
The solicitation includes ILDFA which is a new technology that is an alternative to Aqueous Film Forming Foam (AFFF) fire suppression systems. ILDFAs are permitted by Interim Technical Guidance (ITG) FY22-01, National Fire Protection Association (NFPA) 409 Standard on Aircraft Hangars, and Factory Mutual Global (FM) for fire protection of aircraft hangars.
This acquisition will solicit proposals as an unrestricted full and open, stand-alone construction solicitation as authorized by the approved DD2579 on 25 April 2025. The estimated value of the work included in the construction solicitation is approximately of which is estimated for Ignitable Liquid Drainage Floor Assemblies (ILDFA). The project will be funded by FY24 Military Construction (MILCON) funds. The work under this contract is required to be completed within 1017 days after award.
4. Statutory Authority Permitting Other Than Full and Open Competition.
The statutory authority for this acquisition permitting other than full and open competition is 10 U.S.C.
3204(a)(1) which permits the use of limited suppliers when it is essential to the Government’s requirements, as implemented by Revolutionary Federal Acquisition Regulation (RFO) 6.103-1, Only one responsible source and no other supplies or services will satisfy agency requirements.
J&A No. ML-26-50
5. Rationale Justifying Use of Cited Statutory Authority.
The aqueous film forming foam (AFFF) used in traditional systems became an environmental liability for the Navy. AFFF was prohibited for use after 1 October 2024 by the National Defense Authorization Act for Fiscal Year 2020 (NDAA FY20). The ILDFA is a new approach to address flammable liquid fuel fires in aircraft hangars. The ILDFA uses a passive containment system to contain and flush away any flammable liquid spill or fire. The system does not use any toxic foam chemicals. The system requires far less water infrastructure and less maintenance resulting in lower sustainment costs and a more reliable system over time. Currently, ILDFA is the only alternative technology providing reliable aircraft protection with zero environmental impact.
6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.
There is only one known manufacturer who can provide alternative technology providing reliable aircraft protection with zero environmental impact.
A sources sought notice was published on Sam.gov on 16 March 2026 detailing the requirements of the Ignitable Liquid Drainage Floor Assemblies (ILDFA). The notice sought commercially available products that could meet the same requirements. The response date was 31 March 2026, and no responses were received.
A solicitation notice is publicized on SAM.gov, in accordance with the requirements of RFO Part 5. The approved J&A will also be made publicly available as required by RFO 6.105.
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 RFO Part 15 prior to contract award. Analysis will be performed by one or more of the following techniques: (1) Comparison of proposed prices received in response to the RFP; (2) Comparison of proposed prices with the Independent Government Cost Estimate (IGCE); (3) Comparison of proposed prices with available historical information; and/or (4) Comparison of market survey results.
The fair and reasonable determination will be made based on the total price of the project. This proprietary item is not an individual line-item price in the solicitation.
8. Actions to Remove Barriers to Future Competition
For the reasons set forth in Paragraph 5, NAVFAC Mid-Atlantic has no plans at this time to compete future contracts for the types of supplies/services covered by this document. If another potential source emerges, NAVFAC Mid- Atlantic will assess whether competition for future requirements is feasible.
J&A No. ML-26-24
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