Scrubbers_JA_Redacted.pdf

PHNSY&IMF Code 410 – Contracting Department Annex 1 (NMCARS Change 26-04) Page 1 of 4 08/2026

J&A No. 026167 Code: 400

P.R. Number: TBD

JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity

The Naval Sea Systems Command, Pearl Harbor Naval Shipyard and Intermediate Maintenance Facility (PHNSY & IMF) Contracts Division C400.

2. Description of the Action Being Approved

Award of a contract on a sole source basis for repair actions to a Virginia-class submarine’s No. 1 & No.2 CO2 Scrubbers.

3. Description of Supplies/Services.

a. Removal, refurbishment and re-installation of No.1 & No.2 CO2 scrubbers onboard a Virginia-class submarine. Work was identified by the project team and deemed to be mandatory by Engineering and Planning Department (EPD).

b. The total estimated dollar value: $565,000.00

c. Funding: FY27, O&MN

d. Period of Performance: 19 OCT 2026 – 31 MAY 2028

The Government’s minimum needs have been verified by the certifying technical and requirements personnel.

4. Statutory Authority Permitting Other Than Full and Open Competition

10 U.S.C. 3204(a)(1), Only one responsible source and no other supplies or services will satisfy agency requirements.

10 U.S.C. 3204(a)(2), Unusual and compelling urgency.

10 U.S.C. 3204(a)(3), Industrial mobilization; engineering, developmental, or research capability;

or expert services.

10 U.S.C. 3204(a)(4), International agreement.

10 U.S.C. 3204(a)(5), Authorized or required by statute.

DEPARTMENT OF THE NAVY

PEARL HARBOR NAVAL SHIPYARD

AND INTERMEDIATE MAINTENANCE FACILITY

667 SAFEGUARD STREET, SUITE 100

JBPHH HAWAII 96860-5033

Annex 1 (NMCARS Change 26-04) Page 2 of 4 08/2026

10 U.S.C. 3204(a)(6), National Security.

5. Rationale Justifying Use of Cited Statutory Authority

Per Engineering Planning Department (EPD), Cepeda is the Original Equipment Manufacturer (OEM) of the CO2 scrubber systems deployed on 774 Virginia-Class submarines. Cepeda has designed, manufactured, tested, serviced, and refurbished the CO2 scrubber system. Cepeda owns the drawings, and proprietary procedures and equipment necessary to complete the required removal, refurbishment and re-installation of the units.

Cepeda has not shared their drawings or proprietary equipment and procedures with any entity, including the Government. Because Cepeda does not share any of the drawings, proprietary equipment or procedures necessary to complete this work, they do not certify or authorize any third-party companies/personnel to work on the scrubbers system. As a result, no other sources are capable of accomplishing this requirement as no one else has the necessary procedures, drawings, and equipment. Cepeda is the only responsible source fully capable of satisfying the agency’s requirements.

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

A sources sought was posted on Sam.gov on 12 August 2026 for five (5) days that included a draft work specification and requested that interested parties submit a capabilities statement explaining their approach and qualification to complete the requirement. The sources sought notice received a response from one company expressing interest, but the company did not submit a capability statement, therefore the interested party could not be further evaluated for capability to be able to perform this requirement. Therefore, it is determined that there are currently no known sources other than Cepeda that are fully capable of satisfying the agency’s requirements.

The previous and most recent contract award (N32253-25-C-0004) for a similar requirement that also involved scrubber work was solicited as sole source. Additionally, a sources sought for a similar requirement involving scrubber work (USS JEFFERSON CITY (SSN 759)) was posted on 08 July 2026 and received one response from an interested company. As the interested company did not submit a capability statement, it was determined that there are currently no known sources other than Cepeda that are fully capable of satisfying the agency’s requirements.

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. The Contracting Officer’s determination of fair and reasonable price will be based on price and cost analyses in accordance with Revolutionary FAR Overhaul (RFO) 15.404-1 Price Analysis and RFO 15.404-2 – Cost Analysis.

8. Actions to Remove Barriers to Future Competition

For the reasons set forth in Paragraph 5, PHNSY & IMF has no plans at this time to compete future contracts for the types of supplies/services covered by this document. PHNSY & IMF will

Annex 1 (NMCARS Change 26-04) Page 3 of 4 08/2026 assess whether competition for future requirements is feasible should another potential source(s) emerge.