Redacted Justification.pdf

DEPARTMENT OF THE NAVY

NAVAL AIR WARFARE CENTER AIRCRAFT DIVISION

JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity.

Naval Air Warfare Center Aircraft Division (NAWCAD) Lakehurst, NJ

2. Description of the Action Being Approved.

This Justification and Approval (J&A) authorizes on a sole source basis, a Firm Fixed-Price contract to Precision Custom Components (PCC) located in York, PA (CAGE: 1P555) for the manufacture and delivery of Improved Low Loss Launch Valve (ILLLV) Bodies, P/N 626769-1 in support of the Prototype, Manufacturing, and Test Department (PMTD) ILLLV Overhaul Program. The ILLLV Bodies are required to be delivered beginning in October 2025. This requirement is for a total of 14 ILLLV Bodies, P/N 626769-1, a quantity of six for the base period, a quantity of six for the first option period and a quantity of two for the second option period.

3. Description of Supplies/Services.

ILLLV Bodies are a Critical Safety Item (CSI) subcomponent of the ILLV, which is a CSI part integral to the operation of the aircraft carrier steam catapult. New ILLLV Bodies are required because ILLLV Bodies may only be overhauled a finite number of times before they have to be replaced, and the existing Fleet inventory is aging.

Furthermore, PMTD is overhauling an increased number of ILLLV Bodies yearly due to the accelerated replacement plan, a mitigation step of Risk R-LCHR-19-004. R-LCHR-19-004 is the risk of ILLLV assemblies catastrophically failing in-service due to cracked Plugs. Based on the overhaul records of existing assets and the rejection rate trend, it is projected that PMTD will be unable to meet fleet requirements by 2025. In order to meet the fleet requirement, PMTD requires that the first ILLLV Body be delivered to NAWCAD Lakehurst by October 2025.

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

10 U.S.C. 2304(c)(1), as implemented by FAR 6.302-1, Only one responsible source and no other supplies or services will satisfy agency requirements.

5. Rationale Justifying Use of Cited Statutory Authority.

The ILLLV Body is a designated Aircraft Launch and Recovery Equipment CSI. DFARS 209.270-3(a) states, “The head of the contracting activity responsible for procuring an aviation or ship critical safety item may enter into a contract for the procurement, modification, repair, or overhaul of such an item only with a source approved by the head of the design control activity."

Technical Data Requirements (TDR) 21-17034, regarding the procurement of the ILLLV Body, identifies only one approved and validated source, PCC in York, PA. In order to award to any other company than PCC, an engineering and quality assurance audit would need to be performed on an interested company. The audit process generally takes 12 months, which is an unacceptable delay to contract award and delivery.

The ILLLV inventory is life limited and cannot be used/overhauled indefinitely. Launch valves are limited to 40,000 shots or approximately 12 years in service before requiring overhaul.

Furthermore, NAWCAD Lakehurst Engineering has limited launch valves to two overhauls due to material condition. Based on these requirements, NAWCAD Lakehurst Engineering maintains a replacement plan for all launch valves in the Fleet. In 2016, NAWCAD Lakehurst Engineering identified a serious issue with all of the launch valves in the Fleet. Several plugs were found to have severe cracks due to environmentally assisted cracking initiated at multiple corrosion pits.

The plug base material, 9310, has been deemed not suitable for the environment the ILLLV is subjected to and is the root cause of the crack. A System Safety Risk Assessment was developed for this issue and the risk was qualitatively assessed as Identification, Catastrophic-Remote (Unlikely, but can be reasonably expected to occur) by the Technical Area Experts and System Safety. To mitigate this risk, an accelerated replacement plan was developed to remove and replace valves at approximately eight years or less in service.

To meet this accelerated launch valve replacement plan, new launch valves are required to replace launch valves that are beyond overhaul. PMTD will run out of ILLLV Bodies to overhaul in October 2025. Major launch valve component procurements are required to build new valves. Based on previous procurements, production lead-time is anticipated at 48 months.

This schedule projects delivery after the required delivery date of October 2025. If this requirement is delayed, launch valves will not be able to be replaced as required. As a result, catapults will either have to be placed in down status degrading the operational readiness of the aircraft carrier or the valves will have to remain in service at increased risk of catastrophic failure resulting in loss of aircraft and life. A down catapult also results in reduced sortie mission capabilities rates which not only degrades operational capability readiness, but negatively impacts pilot training. Unavailable catapults add undue burden to ship personnel who now have to plan and execute workarounds, to try to reduce the impact, by increasing preventive maintenance to the remaining catapults to ensure those remain operational.

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

Market research was conducted and confirmed that PCC is the only source that can provide ILLLV Bodies that meet PMTD’s requirements. The Sources Sought notice required by DFARS 206.302-1(d) was published on the beta.SAM.gov website 20 December 2021 and closed on 04 January 2022. Responses were received from Lindquist Machine Corporation, CAGE 2V711, and Ross Precision Machining, CAGE 7JFW8. Both companies were advised of the Source

Approval Request (SAR) process. Both companies were provided the documents that are required in the SAR package in order for the Government to determine whether the company can be added as an approved source on the TDR for competing in future requirements. However, due to the time constraints outlined above, neither vendor can be added to the TDR in sufficient time to be able to compete on the current requirement. The synopsis required by FAR 5.201 was published on the beta.SAM.gov website on 04 January 2022. The synopsis closed on 19 January 2022 with no inquiries received.

The Sources Sought notice and synopsis were republished due to the procurement strategy changing from one contract for the full requirement to a base contract with options. The Sources Sought notice was republished on the beta.SAM.gov website on 18 January 2022 and closed on 24 January 2022 with the same two vendors providing responses. Due to the time constraints outlined above, neither vendor can be added to the TDR in sufficient time to be able to compete on the current requirement. The synopsis was republished on the beta.SAM.gov website on 24 January 2022. The synopsis closed on 08 February 2022 with no inquires received.

A Request for Information (RFI) was posted for the previous procurement in 2013. No responses were received. Naval Supply Systems Command (NAVSUP) initiated another procurement in October 2019, which was ceased in May 2021. No approved sources were added to the TDR from their actions taken.

7. Determination of Fair and Reasonable Cost.

The Contracting Officer has determined the anticipated cost to the Government of the supplies/services covered by this J&A will be fair and reasonable.

8. Actions to Remove Barriers to Future Competition.

PMTD will update market research and will post a RFI every 12 months to determine if a competitive environment exists for future procurements. The Requirements Activity will follow up with NAVSUP every 12 months and prior to exercising options, to request the status of the SAR packages that have been sent to vendors and if the vendor has started the SAR process.

Additionally, PMTD will evaluate the documentation submitted by Lindquist Machine Corporation and Ross Precision Machining and will add them to the TDR if they are deemed capable of meeting the Government’s requirements.

In accordance with Aviation CSI Management Handbook dated 16 March 2011, CSIs shall be purchased or repaired/overhauled only from sources approved by the Service Engineering Support Activity (ESA) in accordance with United States Code Title 10, Section 2319. Alternate sources shall be revalidated by the Service ESA to ensure they remain capable of delivering satisfactory items if they have not delivered or repaired/overhauled the specific CSI to the DoD within three years of an anticipated solicitation.

Because this effort is a follow-on for supplies previously awarded on a non-competitive basis, in accordance with DFARS PGI 206.304(a)(S-70)(i), the prior justification is provided to the approval authority for review. Approval of this J&A signifies the approval authority has made the determination required by DFARS PGI 206.304(a)(S-70)(ii).