final_SSJ_for_APP-ORD-16-00036.docx

SOLE SOURCE JUSTIFICATION

Semi-Continuous Metals Monitor IAW FAR 13.106-1(b)(2)

I. DESCRIPTION OF THE SUPPLIES/SERVICES: In support of the ORD’s Air, Climate, and Energy (ACE) program and EPA’s National Risk Management Research Laboratory’s (NRMRL), research into the emission characterizations from stationary sources is necessary. While there are many pieces of equipment, instrumentation, and methods at the disposal of the involved principle investigators, there is currently no capability in-house for measuring stack level emissions of metals. For current and upcoming studies it is necessary to have these metal monitoring capabilities, thus a semi-continuous metals monitor is desired for purchase.

II. STATEMENT OF FACTS JUSTIFYING SOLE SOURCE AWARD: Providing emissions characterizations from stationary sources is a primary responsibility of EPA’s ORD. With current and upcoming regulations, it is necessary to be able to provide our partners with realistic emissions characterizations from many sources. Currently, emissions from coal-fired utilities are under great scrutiny as many of the hazardous air emissions are difficult to measure. Metals fall into this category, and previously we have relied solely on filter collections of particulate that are later sent to laboratories (often external to EPA costing valuable time and funding) for analysis of metal compounds and concentrations. NRMRL’s ORD would like to bring this capability in-house in order to avoid second party analysis. Further, there is newer technology available that eliminates the need for filter sample collections followed by laboratory analyses, and replaces it with autonomous, semi-continuous measurement of metal emissions. This not only reduces the need for external analysis, but further allows for better characterization of emissions from sources where the combustion is not necessarily steady-state (i.e. where emissions levels vary due to combustion inefficiencies or changes in fuel types, etc.). For these reasons, it is necessary to procure an instrument that is capable of meeting these experimental needs, and the Cooper Environmental Services, LLC Xact 640 is the only instrument available that can meet the Government’s minimum specifications.

EPA’s coal-fired combustion facility (MPCRF), has previously been extensively modified to allow the Xact 640 instrument to interface with the current combustor. The manufacturers of the Xact 640 performed beta tests successfully on the MPRCF and to interface and beta test a different instrument would be cost prohibitive and would take too much time on the combustor which is expensive to run. There exists only a small subset of manufacturers that produce stack emissions monitors that provide real-time or semi-continuous measurements. Cooper Environmental Services, LLC is currently the only known company that has the technology necessary and manufactures a semi-continuous, autonomous, stack-level metal emissions monitor – the Xact 640 Metals Continuous Emissions Monitoring System. Therefore, it is required to have the Cooper Environmental Services, LLC Xact 640 metals monitor in order to work seamlessly with the facility to meet our measurement needs. Market research has demonstrated that no other instrument is on the market that meets and/or exceeds the minimum specifications (provided in separate document) required for the Government’s testing purposes.

III. Cooper Environmental Services, LLC is the only known source able to meet or exceed the Government’s minimum requirement(s) because no other company manufactures an instrument with the ability to make semi-continuous, stack-level, multi-metal emissions measurements.

IV. STATEMENT OF ACTIONS TAKEN TO PRECLUDE THE NECESSITY FOR FUTURE SOLE SOURCE ACQUISITION FOR THE SAME SUPPLIES/SERVICES: Market research conducted (including internet searches and conversations with scientific experts and vendors in this field) indicates that no other manufacturer can offer a metals monitoring instrument that meets or exceeds all of the Government’s minimum specifications.

ORD/NRLRML/APPCD/APTB