J&A_-_14-D-0002_Okinawa_ext_-_redacted.pdf

Justification and Approval for other than Full and Open Competition Extension of Services, Okinawa Japan, Off Island Disposal SP453014D0002

1. Contracting Activity: DLA Disposition Services, J-763

2. Description of Action: Contract SP4530-14-D-0002 was awarded on 07 December 2013 to Kankyo Solution CO (Kankyo) with an effective date of 20 December 2013. Both option periods on this contract have been exercised. The Second Option Period, which is the final option period, will expire on 16 June 2018. As a result of unanticipated delays in awarding the renewal contract, the Second Option Period will be extended six months, resulting in an expiration date of 16 November 2018

The current total estimated

3. Description of Supplies/Services: This is a recurring requirement for services to provide hazardous waste removal, transportation and disposal from various military and US Government locations in and around the Okinawa Japan. The requirement includes disposal of hazardous waste consisting of types of industrial waste, hazardous sludge (oxidizers, corrosives, flammable), waste oil, waste acid, waste alkali, and compressed gas cylinders.

4. Authority Cited: 10 U.S.C. 2304(c)(1), Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements as authorized by FAR 6.302-1.

5. Reason for Authority Cited: 10 U.S.C. 2304(c)(1), as implemented by FAR parts 5.202(a)(11) and 6.302-1, only one responsible source and no other services will satisfy the requirement is cited. Not exercising the option would cause unacceptable delays in fulfilling the Government’s requirement for these services. (See 10 U.S.C. 2304(c)(1) or 41 U.S.C. 3304(a)(1)). The proposed contract modification will be issued pursuant to the authority of FAR 52.217-8, Option to Extend Services, which is included in the current contract.

The Government has a need to extend the Second Option Period by an additional six months to allow sufficient time to award a replacement contract. The Okinawa contract requires uninterrupted hazardous waste disposal/management services to meet their mission, and to remain environmentally compliant and safe. Changes in pre-award requirements for this action would require a longer period of time to provide the services required and would result in a break in service for the customer. A break in service would result in serious financial injury to the Government. Any disruption to the services currently being performed under contract SP4530-14-D-0002 would lead to a disruption or mission failure.

Without contract coverage the area is at a high risk of compliance issues regarding the regulatory storage time limits, as they already have a significant amount of hazardous waste requiring removal. These are critical services, as no hazardous waste products may exceed local storage time period for shipment to an off-site disposal facility. If the local regulatory timeframe is exceeded, the installation may be subject to fines up by the host countries regulatory body.

6. Efforts to Obtain Competition: It is not practical, nor in the Government’s best interest, to competitively award a bridge contract for the interim period between the end of the current contract and the award of the follow-on procurement. The competitive process does not allow sufficient time to acquire services for the interim period. The average DLA Disposition Services J-76 procurement lead time, as defined as the time a purchase request is received until a contract is signed, is 256-days based on a 3-year average. Given the current procurement lead time it is not possible to compete and award the replacement contract or a competitive short term bridge contract prior to 16 June 2018. Kankyo is the only responsible source that can currently continue to meet the Government’s need for critical hazardous waste removal and disposal services. Kankyo is the incumbent contractor, and already has personnel and equipment mobilized to perform the required work during the interim period.

Transferring this work to another contractor would incur substantial duplication of cost and adversely impact required performance timeframes.

7. Price/Cost Consideration:

8. Market Research: It is determined that a market survey is impractical, as it would not generate any additional sources capable of satisfying the requirements within the urgent time extension required. In addition, a new IDIQ contract will replace the current contract SP4530-14-D-0002 with Kankyo. As listed above, Kankyo currently has personnel and equipment mobilized to perform the required work during the interim period. Kankyo has the knowledge and experience required to maintain uninterrupted hazardous waste services. Transferring this work to another contractor would incur substantial duplication of cost and adversely impact the requirement performance timeframes. Any disruption in the current performance timeframes could adversely affect the mission and could put this at risk of regulatory storage violations. These are critical services, as no hazardous waste products may exceed local storage time period for shipment to an off-site disposal facility. If the local regulatory timeframe is exceeded, the installation may be subject to fines up by the host countries regulatory body.

9. Actions Being Taken to Overcome Barriers to Competition: A competitive solicitation for a replacement contract is anticipated and will be awarded as soon as practicable.

10. Other Facts: N/A

11. 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.

DATE:_ ____ ____________________________________

Paul Raduziner Environmental Protection Specialist

RADUZINER.PAUL.B

RYAN.1162680451

Digitally signed by

RADUZINER.PAUL.BRYAN.116268

Date: 2018.04.24 15:21:52 -10'00'