REDACTED Limiting-Competition-under-SAT_ACC.docx

Control No:

Memorandum for Record – Limiting Competition at or below the Simplified Acquisition Threshold

1. Contracting Activity: Army Contracting Command Redstone Arsenal Corpus Christi Army Depot, Contracting Office (CCAM-ALC) 9035 Ocean Dr. Bldg. 10, Mail Stop 18 Corpus Christi, TX 78419-5260

2. Description of Action:

Nature: New Requirement

Order #_______ against a single award IDC Contract Modification # _______ to existing PO/TO/DO/Call Order #________________

Pricing/Contract Type: Fixed Price Time & Materials/Labor Hours Cost Reimbursable Hybrid

Funds: Operations & Maintenance, Army (OMA) Other Funds: Army Working Capital Funds, FY: 2021

Name of Proposed Contractor(s) and Address:

Marietta Nondestructive Testing, (CAGE CODE: 5ZCE0, Business Size: Small) 530 Commerce Park Drive Marietta, GA 30060-2782

Brand Name Buy: Yes No

3. Description of Services or Supplies: To procure an upgrade for the Marietta Digital Radiography Inspection System (DRIS), Varex 4343 Flat Panel Image Detector, Yxlon Imaging Kit, Monitor, Installation and freight costs used by Corpus Christi Army Depot Material Processing Engineering Divisions Non – Destructive Testing (NDT) Program Management Office. The DRIS is not in compliance with today’s industry controlling American Society for Testing and Materials (ASTM) E2698 and E2737 Standards on digital radiography systems that use Digital Detector Array (DDA) panels for capturing and processing images. The Marietta DDA inspection system produces and evaluates radiographic images of welds made on various alloys of metal by welding shop artisans. The system evaluates each radiographic image to determine if the quality of the weld made by the artisan meets aerospace welding quality requirements for certification. The system also provides support to CCAD Analytical Investigation Branch when detailed internal images is required to assist with the evaluation of an aircraft mishap investigation.

Hamamatsu Micro Focus X-ray Source

Total

Delivery Date Estimation: 30 December 2020 Total Value: $_______________

4. Authority: FAR 13.106-1(b)(1): For purchases not exceeding the simplified acquisition threshold (SAT), only one source reasonably available, urgency, exclusive licensing agreements, brand name, or industrial mobilization.

5. Reasons for Authority Cited: Corpus Christi Army Depot (CCAD) Non-Destructive Testing Program Office uses the Marietta Digital Radiography (DDA) Inspection System to provide support to the Corpus Christi Army Depot (CCAD) Welding Program’s certification of personnel and equipment. The Marietta Digital Radiography (DDA) Inspection System produces and evaluates radiographic images of welds made on various alloys of metal by welding shop artisans. The system evaluates each radiographic image to determine if the quality of the weld made by the artisan meets aerospace welding quality requirements for certification. The system also provides support to CCAD Analytical Investigation Branch when detailed internal images is required to assist with the evaluation of an aircraft mishap investigation. The current Marietta Digital Radiography (DDA) Inspection System does not meet today’s American Society for Testing and Materials (ASTM) E2698 and E2737 Standards as the industrial digital radiography with DDA panels controlling standards for systems performance and quality.

The proposed acquisition requires the use of the cited statutory authority because, all Mechanical and Electrical Drawings for the Vault and wiring are Intellectual Property (IP) to Marietta Nondestructive Testing, LLC (Cage Code 5ZCE0), 530 Commerce Park Dr. SE, Marietta, GA. 30060. Marietta is the OEM and original designer and installer of the system and holds all rights to the data and components. Although some components such as the X-Ray tube head and detector are off-the-shelf parts, the installation is proprietary, and the hard parts need to meet the tolerances set by the OEM to maintain system compatibility, safety and reliability. All new parts must be fully integrated with the rest of the system including the proprietary carriage. There is no other known source that has the knowledge, ability to read, modify, or maintain any of the software or technical data associated with the system currently in place.

6. Publicizing Contract Actions: For FAR Part 13 actions, the public display and synopsis requirements of FAR 5.101 and FAR 5.203 do not apply due to the $ threshold, apply and will be followed, or do not apply due to an exception at 5.202 ______________________.

Requirement to post justification in accordance with FAR 8.405-6(b)(3), FAR 13.105(c), or FAR 16.505(a)(4)(iii)(A) Action is NOT a brand name restriction and is under $150K, no posting required Action is a brand name restriction, under $25K, no posting required Action is a brand name restriction, over $25K. It will be redacted and posted with the solicitation.

Action is a brand name restriction over $25K but will not be posted due to exception:

FAR 8.405-6(b)(3)(iii)(B)

7. Market Research: Market Research was conducted on 27 April 2020 by Victor Manuel Moreno, Equipment Specialist who has Knowledge has been obtained through over 12 years of work experience; along with several years of having written numerous contracts procuring both supplies and services through the contracting office for the Corpus Christi Army Depot.

Contact with knowledgeable persons in Government and/or industry regarding the commercial nature of this requirement and/or standard industry practice in this area of supplies/services: On 7/06/208 Mr. Moreno contacted John Quesada, Quality Assurance Specialist (NDT), Material Engineering Branch 961-0253, he provided the updated market research quote on 3/19/2020 from the vendor Marietta X-Ray and the SOW. He stated that the Marietta Digital X-ray System has outdated subsystem components and data acquisition software that needs to be upgraded in order for the Marietta X-ray system to be in compliance with industry quality control requirements and standards. John Quesada does not have knowledge of commercial marketplace, but he is NDT III certified and is the Subject Matter expert for the Digital X-Ray Systems.

Results of recent market research review for similar or identical supplies/services: During Mr. Moreno’s research he found that the Marietta NDT, LCC (OEM) Cage Code: 5ZCE0, can upgrade the current Marietta Digital X-ray System and data acquisition software to produce a turn-key system that is compliance to the industry quality assurance standard and requirements. On 3/19/2020 - Marietta NDT, LCC. - (OEM) Market quote provided.

Other Types of Market Research and date performed:

On 21 August the Contract Specialist utilized the search engine Google and found information on the x-ray upgrades for the NDT from a few companies, but only the brand name Marietta NDT shows that Marietta can provide the upgrade as shown on the following link: https://www.google.com/search?q=Marietta+Digital+Radiography+Inspection+System+Upgrade+system&source=lnms&sa=X&ved=0ahUKEwihr5KysKzrAhV1gnIEHf9SBg4Q_AUIkwIoAA&biw=1920&bih=934#spf=1598015715932

8. Other Facts: W58RGZ-15-C 0084, awarded on 9/17/2015 to VJ Technologies for $867,957.00.

9. Technical/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. Reference Sole Brand Name Justification signed by Kelman Forrest, Systems Engineering Division, Directorate of Production Engineering on 24 August 2020.

10. Contracting Officer Certification/Approval:

I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable based upon analysis and market research.

I certify that this justification is accurate and complete to the best of my knowledge and belief, and that completing this purchase as a sole source is in the best interest of the Government. Additionally, I approve this justification to limit competition subject to the availability of funds and provided that the services or supplies herein described have otherwise been authorized for acquisition.

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