W9127820R0113 Signed SAM_JA_Brand Name GDACs Hydropower.pdf

JUSTIFICATION REVIEW DOCUMENT – JUSTIFICATION AND APPROVAL (J&A)

CONTROL # SAM 20-0006

Project/Equipment SAD Control Cabinet Supply / Allen-Bradley PLCs, SoftPLC, Monaghan SER, SEL Relays, Cisco Switches, Prosoft Modules, and LuxLink IRIG Transceivers

Authority: 10 U.S.C. 2304(c)(1) and FAR 6.302-1 AMOUNT $6,000,000.00

Prepared by:

Name: Nathan Britt Telephone: (706) 566-9673

Title: Electrical Engineer Date:

Contracting Officer (See Sections 13-14 Below)

Name: John C. Vandiver Telephone: (251) 441-5447

Title: Contracting Officer Date:

Technical (See Section 11 Below)

Name: Nathan Britt Telephone: (706) 566-9673

Title: Electrical Engineer Date:

Requirements (See Section 12 Below)

Name: Bobby L Earley Telephone: (251) 690-2643

Title: Supervisor Electrical Engineer Date:

Signatures Are Required Below:

I have reviewed this J&A and find the justification adequate to support other than full andopen competition.

Deputy for Small Business Signature: Date:

Name: Linda L. Spadaro Telephone: (251) 441-3597

Project Manager (If no PM, use N/A)

Signature: Date:

Name: Matthew Dunn Telephone: (251) 694-3694

Office of Counsel (OC) Signature: Date:

Name: Telephone:

Business Oversight Branch (BOB) Chief

Signature: Date:

Name: James K. Kiesling Telephone: 251-441-5591

District Contracting Chief

(DCC)

Signature: Date:

Name: Jeffery D. Burgess Telephone: 251-441-6501

SPADARO.LIND

A.L.1230756470

Digitally signed by

SPADARO.LINDA.L.1230756470

Date: 2020.07.15 19:17:54 -05'00'

DUNN.MATTHE

W.T.1249358564

Digitally signed by

DUNN.MATTHEW.T.1249358564

Date: 2020.07.20 12:21:04 -05'00'

BRASFIELD.DAVID.CA

RLTON.JR.125460655

Digitally signed by

BRASFIELD.DAVID.CARLTON.JR.1

254606550 Date: 2020.07.21 09:55:25 -05'00'

KIESLING.JAME

S.K.1404306398

Digitally signed by

KIESLING.JAMES.K.1404306398

Date: 2020.07.22 13:11:02 -05'00'

BURGESS.JEFFERY.D.1264843584 Digitally signed by BURGESS.JEFFERY.D.1264843584 Date: 2020.07.22 13:55:16 -05'00'

Control # SAM 20-0006

Justification and Approval For

Other than Full and Open Competition

The following Senior Contracting Official, Atlanta (SCO-ATL) signature indicates concurrence with the contents of this Justification:

SCO-ATL

Counsel

Signature Date

Justification and Approval For Other than Full and Open Competition

1. Contracting Activity: U.S. Army Corps of Engineer (USACE), Mobile District, 109 St.

Joseph Street, Mobile, Alabama 36604-0001.

2. Description of Action: CESAM plans to place seven brand name specifications for $6,000,000.00 worth of integral parts for control cabinets. These control cabinets are requirements of the Generic Data Acquisition and Controls System (GDACS) and the Controls Upgrade projects planned for 13 powerhouses in South Atlantic Division (SAD). This J&A is for brand name items that will be placed inside control cabinets provided by the contractor. This solicitation will result in a SATOC that covers all 13 hydro-power projects in the South Atlantic Division. The supply of the cabinets will be procured through an Indefinite Delivery Indefinite Quantity (IDIQ) Single Award Task Order Contract (SATOC). The SATOC will be solicited utilizing competitive procedures but will include specifications for the interiors control components described in this justification. The contractor is to supply complete assembled control cabinets designed and specified by the USACE Hydroelectric Design Center (HDC) Automated Controls and Cyber Security (ACCS) Section. The SATOC contractor will procure all these parts and build a control cabinet. However, the contractor will ship them to the designated project location for final assembly. The SATOC contract could require multiple cabinets to be provided at the same time.

The required brand name produces required to assemble the cabinets include: SoftPLC Corporation (Hardbook), Monaghan Engineering (Sequence of Events Recorder), Cisco (Network equipment), Schweitzer Engineering Laboratories (SEL) (Protective Relays and Revenue Meters), Allen-Bradley (AB) (Control Logix Platform) and LuxLink (IRIG Transmitter/Receiver). A description of the purpose of each component is described below in Paragraph 5. The use of these brand names is essential to the Government’s requirements, thereby precluding consideration of a product manufactured by another company. Funding for this project is non-appropriated Civil Works River and Harbor no-year funds authorized by the Water Resource Development Act (WRDA), Section 212.

3. Description of Supplies/Services: The control cabinets will provide control and protection functions for the hydroelectric generators and ancillary equipment at 13 powerhouses within SAD. Each powerhouse needs at least two cabinets per hydroelectric generator but more than two may be needed depending on the condition and age of the controls and protection of the generator. The cabinets will also serve as an interface between the operator workstation (computer) and physical powerhouse systems. These new control cabinets and components contained inside will bring the SAD projects up to current cyber security standards. The contractor will supply the control cabinets as designed and specified by USACE in each task order to the SATOC. Separate task orders will be issued for each of the 13 powerhouses. All the listed brand specific components are off-the-shelf equipment. The specified equipment constitute approximately 60% of the cabinets to be assembled onsite from individually delivered components. All the parts identified are components to these cabinets that ensure interoperability and continuity throughout SAD powerhouses. There will be some components, such as wire, that are not brand specific.

Brand Name Product SoftPLC Corporation Hardbook Monaghan Engineering Sequence of Events Recorder Cisco Network equipment SEL Protective Relays and Revenue Meters Allen-Bradley ControlLogix Platform ProSoft Modbus Communication Module LuxLink IRIG Transmitter/Receiver

The total capacity of this SATOC will be $6,000,000. The listed brand names for justification are installed across the nation in hydropower facilities, many in SAD hydropower facilities. The SoftPLC Corporation Hardbook is installed in ever facility that is running on the Hydro Electric Design Center’s (HDC) Generic Data Acquisition and Controls System (GDACS). These controllers cost about $5,000 each. The Monoghan Engineering sequence of events recorders are installed in the control cabinets where GDACS are used. These event recorders are about $2,000 each. The Cisco network equipment is installed at all 13 hydropower facilities in their existing control systems. This network equipment cost about $2,000 each. The SEL protective relays are installed at all 13 projects with line relay protection and the projects that have undergone a generator relay protection upgrade. These relays cost about $4,000 each. The Allen-Bradley ControlLogix Platform is installed at all the 13 projects and at any facility that has undergone the GDACs upgrade. These components cost about $1,000 each, but some components can reach up to $10,000. The ProSoft Modbus Communication Modules are installed at all hydropower facilities that have GDACs. These communication modules cost about $2,400 each. The LuxLink IRIG Transmitters are installed in control cabinets across the nation that have the GDACs system. These transmitters cost about $1,000 each.

4. Authority Cited: The statutory authority permitting acquisition of the requirement by other than full and open completion is 10 U.S.C. 2304(c)(1) as implemented by FAR 6.302-1(a)(2), Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. This authority is applicable to brand name justifications in accordance with FAR 6.302-1(c)(1).

5. Reason for Authority Cited:

Background:

The existing generator control systems at all the hydropower facilities in this J&A are over twenty years old. Most projects have control systems that are over fifty years old. The life span of a control system should not exceed twenty years. The risk of failure increases the older the equipment is in service. Current cyber standards exist to protect the equipment in the powerhouse. The existing old equipment does not meet current standards for cybersecurity. The new equipment will allow HDC to handle the yearly cyber security audits on the powerhouse bringing SAD up to national cyber security requirements. Because all of the hydro power facilities in SAD have out of date control systems, it has been decided to make this a division wide effort. In order to maintain consistency in the build materials and style it has been decided to make this a SATOC. A single contractor building these cabinets across SAD will ensure that electricians and engineers can move between hydropower facilities and have familiarity with the control system.

The existing control system is out of date and in need of replacement. The cabinets are necessary for this new control system. If the existing controls fail at a hydropower facility, generator downtime will occur. Downtime is a critical factor with Hydro-electric projects. When there is a generator outage at one of the SAD hydropower facilities, it reduces the overall hydropower capacity and energy available to South Eastern Power Administration (SEPA) within the control area. This results in our customer (SEPA) being unable to meet their contractual obligations with their preferred power customers because USACE was not able to maintain its current hydro production. This forces SEPA to purchase power on the open market at higher rates to meet those obligations. Financial data compiled from the Environmental Impact Statement (EIS) used in the Water Control Manuals, specifically, the ACT Final EIS for Master Water Manual Updates, Appendix E, ACT Hydropower Impact Analysis Draft, October 2014 and ACF Hydropower Impact Analysis Draft, June 2016, as prepared by the Hydropower Analysis Center confirms that the average daily benefit per SAM Main Unit Generator is $10,723.00 or $3.9M annually.

Justification: In accordance with FAR 6.302-1(c), the brand names listed in this Justification are the only protection and control system pieces that will meet the agency’s needs. The brand names listed demonstrate a unique capability that, if not used, will result in a substantial duplication of cost to the Government in terms of procurement, validation, training and maintenance.

Allen-Bradley: If any other brand is purchased the GDACs Program will have to be rewritten and new software licenses would need to be procured and training conducted. This would be significant duplication of prior efforts. SAD plants already have licenses for Allen Bradley and are already trained on the software. The existing licenses are compatible with the new hardware.

HDC currently performs monthly cybersecurity checks on the system. If a new brand is introduced, it would require HDC to develop and implement an entire new hardware verification program for the new equipment and implement a process to perform monthly checks.

Cisco: If any other brand is purchased, USACE will incur significant labor to redesign the GDACs cyber-security architecture that would not be recovered in competition. Additionally, the HDC team would have to rework all their network protocols, as they are based on current system interfaces. If SAD has a different brand, they will have to perform an entire new hardware verification every month and this will be increased cost to the government they are currently only performing checks on Cisco equipment. Additionally, Cisco is the recognized cyber safe brand by USACE and if another brand is purchased, HDC would have to spend a significant amount of labor validating all cyber-attack elements, which would require having a cyber specialist visit the project and familiarize the workforce in programing new routers and how the new equipment relates to hydropower cyber security further increasing labor and training costs.

LuxLink: If any other brand is purchased significant labor to redesign the standard IRIG program will be needed by HDC and additional software licenses will need to be purchased. The IRIG Transmitters and Receivers are the standard models used at other projects where GDACS is installed. Deviating from the tested hardware configuration would require additional design, testing, and validation for the standard GDACS model. The GDACs remote terminal unit cabinet is cyber security validated as a whole unit. If an alternate version of IRIG Transmitter is purchased the entire remote terminal unit cabinet would have to be certified to cyber security standards.

Monaghan: The SERs specified are the standard model used at other projects where GDACS are installed. This specific hardware is part of the Risk Management Framework (RMF) type certification for the GDACS SCADA system. HDC provides cyber security validation for the Monaghan SERs. Deviating from the standard HDC developed hardware configuration would invalidate the certifications for the GDACS installation. HDC would also have to purchase the alternate brand and test it in their labs resulting in delayed implementation across SAD. HDC would have to keep the alternate brand on hand and test every firmware released for the hardware thus doubling their efforts and greatly increasing project costs and risk.

Schweitzer Engineering Laboratories: SAD has manufacturer-specific software to support the operation and maintenance of existing equipment. Adding additional devices from other manufacturers to the inventory would require the procurement and maintenance of additional manufacture-specific support. This scenario will replicate for every new manufacturer brought onto the facility and would continually add to the indirect overhead costs of maintaining the facility.

SAD has a substantial investment in training employees through manufacturer-specific courses.

The level of sophistication of PLC-related devices requires employees servicing these devices to be manufacturer-trained. Tuition costs, per course, range from $1,200.00 to $3,000.00 per employee. A one-week course per employee easily exceeds $5,000.00 for tuition, airfare, per diem and lodging, and does not include labor costs. There is a minimum of 10 employees that work with embedded controls and protective relays. This financial burden to train the hydropower workforce on multiple manufacturers is clearly not cost effective, nor efficient because it would double the amount of time needed by each employee to service and train on the needed equipment.

SoftPLC: If any other brand is purchased a significant amount of redesign will need to be done by the HDC staff. The GDAC system, since the 1990’s, has been based off the program and hardware of SoftPLC. All GDAC code is written in computer language and converted over to ladder logic for SoftPLC. If any other brand is purchased the entire GDAC program will have to be rewritten. Additionally, new hardware would have to be cyber security re-verified, increasing time until implementation and overall project costs.

ProSoft: If any other brand is purchased, there will be no way to communicate with the new and existing Allen-Bradley system. This is a critical function of the control system. Without this an entirely new control system would have to be redesigned and all other justifications for the other brand name justified equipment will apply.

Alternatives:

Utilize alternate software/hardware in the control groups. e.g. Siemens PLC could be used in place of Allen-Bradley but would require significant cost increases for licensing and training. This route would require the Automated Controls and Cyber Security (ACCS) team to retool for all of SAD. PLCs have proprietary software language; this route would require the HDC design to be completely redone for Siemens software language.

Quasonix could be used in place of Luxlink and would require additional resources in revalidating the transmission and reception of the new system.

Re-engineer the control systems of the power houses to handle generic control boards.

This would require a significant amount of redesign of the already completed design from

HDC.

Use alternative brands and have HDC revalidate and provide cybersecurity testing for SAD separate from the rest of the Corps of Engineers. This cost would be significant and would increase every year.

Have HDC redesign their programing to be able to run on different software based PLCS.

This would require a significant amount of redesign of the already completed design from HDC and then the redesign would need to be implemented.

Impact: If the above alternatives were chosen, SAD projects would incur significant additional yearly maintenance costs associated with increased training and software support contracts that would strain an already tight O&M budget. Additionally, some of the alternatives involve completely redesigning the system. It is hard to put an actual number on time and cost impacts resulting from the trial and error needed to validate the systems provided by different manufacturers. Accounting for communication links across the different equipment manufacturers would require additional design time and collaboration on the front end and would increase the time it takes to complete these type projects. If the government does not use equipment that is tested and validated as cyber-secure, it would make critical assets vulnerable and increase our cyber-security risk. Furthermore, without the IRIG Transmitters and Receivers, the GDACS would lose critical functionality. It is imperative that all devices in the control system that keep time utilize the same source clock. Without proper sequence of event recorders that are compatible with GDACS, we would lose critical functionality and sequencing. It is important that the project operators have sequence of events recorders so they can troubleshoot critical events. Without these products, it increases the risk that generator reliability would be jeopardized due to unfamiliarity and lack of experience with new products and how they interact with each other. Lastly, these proposed alternatives would require a new spare parts inventory be setup to cover all the new products. Those new spare parts would be duplicating the spare inventory of the section 3 brands that are already on site for existing installations and would require maintenance staff additional training on the new products. All of the above stated impacts support the justification of this procurement method and explain why it is vital to sole source these individual components in order to keep operational stability and effectiveness across SAD hydropower.

6. Efforts to Obtain Competition: A Sources Sought was issued in Beta.SAM.gov on April 16, 2020 with a response date of May 19, 2020 to determine market capability for this requirement.

No responses were received. A synopsis of the proposed contract action will be issued IAW FAR

5.201 prior to release of the solicitation. The Cabinet supply will be competitive. This brand name justification supports the sole sourcing of interface portions that must go into the cabinet.

7. Actions to Increase Competition: Efforts to solicit a separate like product would prove incompatible with the existing USACE infrastructure and the existing equipment. The parts listed in the justification are parts of the larger cabinet and need to be sole sourced to ensure the systems operate correctly and do not jeopardize the USACE SAD hydropower mission.

8. Market Research: The Government’s market research included a Sources Sought W9127820R0022 to Beta.SAM.gov on April 16, 2020 for fifteen days to determine market capability for this requirement. The Government did not receive any responses, there were no interest sources.

9. Interested Sources: No Interested Sources

10. Other Facts: NA

11. Technical 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.

Name: Justin N. Britt Title: Technical Manager

BRITT.JUSTIN.NATHAN Digitally signed by BRITT.JUSTIN.NATHANIEL.1395795496 7/15/2020

IEL.1395795496

Signature

Date: 2020.07.15 15:51:48 -05'00' Date:

12. 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.

Name: Bobby L Earley Title: Supervisory Electrical Engineer

Date:

Signature

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable. Fair and reasonable cost will be derived by the evaluation of the open competition supply of the justified brands in this J&A against the Government estimate. In accordance with FAR 15.403-1(b)(c)(C)(3)(i), cost and pricing data is not required.

Name: John C. Vandiver Title: Section Chief, Hydropower Section

Date:

Signature

7/15/2020

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Name: John C. Vandiver Title: Section Chief, Hydropower Section

Date:

Signature

7/15/2020

EARLEY.BOBBY.L.123

0748868

Digitally signed by

EARLEY.BOBBY.L.1230748868

Date: 2020.07.15 16:05:26 -05'00'

Approval:

Based on the foregoing justification, I hereby approve the above stated procurement on an other than full and open competition basis pursuant to the authority of 10 U.S.C. 2304(c)(1) as implemented by FAR 6.302-1, in the amount of $6,000,000.00, subject to availability of funds and provided that the services and property herein described have otherwise been authorized for acquisition.

Approved By:

Date:

Kimberly A. Marshall Alternate Advocate for Competition U.S. Army Corps of Engineers