Redacted - Justification and Approval for Sole Source_CEN LPCO2 Tank_.pdf

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Control Number: LRN-FY25-19

b. Justification: The Nashville District Hydropower Plants and other power generation facilities have standardized fire suppression systems. Standardization is the current industry best practice in regards to safety, operability, and reliability. Since Ansul LPCO2 tanks are no longer serviceable by the manufacturer and commercially ready spare parts are absent, Janus Fire Systems is the only vendor that is setup to replace outdated Ansul tanks. Janus Fire Systems have a sub department called “Hiller Fire” that consists of former Ansul employees leading the industry in Ansul tank replacements that meet all NICET level IV (special hazard fire suppression system designs), FSSA, and NFPA certifications. Hiller Fire is leading the charge for outdated Ansul tank replacement and repairs with their modified Janus Fire Systems tank design.

To ensure continued reliable operation, it’s crucial that the replacement LPCO2 tank matches the existing equipment footprint, relief valves, and all input and output lines. All components within a fire suppression system must function seamlessly together, and even a minor deviation in design can create significant problems that will result in under performance of the whole system. System under performance can cause millions of dollars of damage if the new LPCO2 Tank doesn’t meet the Government expectations.

Specifically, the replacement LPCO2 tank must match the existing unit’s physical dimensions, mounting configuration, electrical specifications, and compatibility with incoming and outgoing lines. Any mismatch would introduce labor intensive trouble shooting requiring extensive and costly rework by our mechanics, electricians, engineers, SCADA specialists, and operators. All generating units will need to be cleared out for outages till the full system is complainant and ready for usage. Extra calculations for anything that is considered a mismatch will introduce uncertainty in the already proven system.

While competition is valued, in this case, it is limited to ensure we obtain the specific equipment needed to maintain the integrity and functionality of our hydropower generation systems and a quick turn around by the already proposed contractors.

c. Alternatives: At this time, alternative solutions are not being considered due to the increased risk the LPCO2 pose to the Government. A comprehensive understanding of critical system characteristics is essential, and any oversight in defining these requirements could result in a component malfunction or the selection of equipment that does not meet project specifications.

To ensure that a fully functioning LPCO2 storage tank is compatible with the existing system, procurement of a brand specific Janus Fire Systems tank is highly recommended. Their products are considered best suited to meet the necessary requirements and maintain system integrity.

d. Impact: Failure to replace the LPCO2 with equivalent replacements presents an elevated risk to hydroelectric generation assets such as stator coils, rotor coils, rotor, shaft, and the powerplant itself. LPCO2 tanks are critical for rapid and reliable fire suppression, utilizing a fast-acting carbon dioxide dump system that is designed to minimize the impact of transient faults common to power generation facilities directly impacting the inside of the generation equipment. A failure in any of these protection systems would likely result in hundreds of million dollars in damages and significant repair costs. Furthermore, the extensive design, testing, installation, and commissioning required for replacement would substantially disrupt the generating schedule and potentially impact regional electrical demands.

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Maintaining LPCO2 functionality through proper in-kind replacement is therefore paramount to ensuring the continued reliable and secure operation of hydroelectric assets.

6. Efforts to Obtain Competition: There are no other known sources for purchasing the JANUS Fire Systems tank.

A Notice of Intent (NOI) to include the brand name product in the solicitation and to sole source was posted on 8 September 2025 on SAM.gov for seven (7) calendar days. No responses were received from the industry stating they are capable of providing an “equal” that meets the Government’s specifications.

7. Actions to Increase Competition: This J&A supports a discrete requirement that will end when the project is complete. Therefore, there are no planned actions to increase competition for the requirement covered by this J&A.

8. Market Research: A Notice of Intent (NOI) to include the brand name product in the solicitation and to sole source to Hiller Fire was posted on 8 September 2025 on SAM.gov for seven (7) calendar days. The Nashville District received zero responses from industry in regard to the NOI in the time provided.

Upon initial trouble with the storage tank, Center Hill Power Plant reached out to numerous vendors to acquire an Ansul storage tank for replacement over the period of three to four months. After getting directed to other vendors and distributors it was concluded that Ansul no longer makes the storage tanks required for Center Hill’s application. Several vendors suggested reaching out to Janus Fire systems as they would be the only company that could assist Center Hill with its replacement efforts. Janus Fire systems indicated that it has a sub vendor and service provider company, “Hiller Fire,” that specializes in Ansul tank removal and Janus Fire Systems tank installment. Hiller Fire consists of a team of engineers formally with Ansul that are able to change out the Ansul tanks and replace them with Janus Fire Systems tanks. Hiller Fire’s expertise is necessary as a lot of re-engineering and modification needs to take place for the whole fire suppression system to function properly. As of August 2025, Hiller Fire is the only company that has a replacement storage tank on hand and ready for purchase with engineers ready to assist in the modification of the existing system. Hiller Fire is the only registered SAM.GOV vendor deemed acceptable to perform this task at this time.

9. Interested Sources: The NOI revealed no feedback from Industry on the Brand Name and Sole Source synopsis. The Solicitation will be synopsized in accordance with FAR 5.201.

10. Other Factors: None.

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.

Name:

Title: Powerhouse Superintendent

Date: ___________________

Sig ature:______________________ 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.

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Name: Date:_________________________

Title: Area Maintenance Engineer Signature:

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable. This determination will be based upon the Independent Government Estimate and price analysis. Certified cost or pricing data is not required.

Name: Andrew R. Roth Date:

Title: Contracting Officer Signature:______________________

14. Contracting Officer Certification and Approval: I certify that this justification is accurate and complete to the best of my knowledge and belief. Based on the foregoing justification, I hereby approve the procurement of the brand name items listed herein for the Center Hill Dam in Lancaster, Tennessee, estimated at on an other than full and open competition basis pursuant to the authority of 10 U.S.C. 2304(c)(1), subject to the availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

Date: ______________________ Signature Andrew R. Roth Contracting Officer