JA Doble Engineering Company Redacted.pdf

CUI

FAR Part 13 J&A Control # 24-0041

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

CONTROL # SAM 24-0041

Program/Equipment Doble Engineering Company Test Equipment Lease Agreement

Authority: FAR 13.501(a) Commercial Items AMOUNT $

Prepared by:

Name:

Phone:

Title: Field Engineer

Contracting Officer (See Sections 13-14 Below)

Name:

Phone:

Title: Contracting Officer Technical Rep

(See Section 11 Below) Name:

Phone:

Title: Project Manager

Requirements Rep (See Section 12 Below)

Name:

Phone: 7

Title: Field Engineer

Signatures Are Required Below:

I have reviewed this justification and find it adequate to support other than full and open competition

Deputy for Small Business

Signature: Date: (See Signature)

Name: Phone:

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

Signature: Date: (See Signature)

Name: Phone:

Office of Counsel (OC) Signature: Date: (See Signature)

Name: See Signature Phone: (See Signature)

Business Oversight Branch (BOB) Chief

Signature: Date: (See Signature)

Name: Phone:

Chief of Contracting Office (CoCO)

Signature: Date: (See Signature)

Name:

Phone:

FAR Part 13 J&A Modified for FAR Subpart 13.5

1. Contracting Activity: U.S. Army Corps of Engineers (USACE), Directorate of Contracting, Mobile Regional Contracting Center, P.O. Box 2288, Mobile, Alabama 36628-0001.

2. Description of Action: This FAR Subpart 13.5 J&A is requested to procure a lease agreement with Doble Engineering Company for test equipment to be used at hydropower facilities in the Mobile and Savannah Districts (SAM and SAS). The test equipment will be used to assess the condition of generation equipment at these facilities during scheduled maintenance outages. The equipment will also be used in a troubleshooting capacity if/when a failure occurs. The anticipated period of performance is 5 years (one-year base and four one-year options). The funding being used for this action will be FY24 O&M Civil Works.

Per DFARS 213.501(a)(i), the applicability of DFARS PGI 206.304(a)(S-70) was considered for this follow-on acquisition. All previous procurements for this requirement were valued below the simplified acquisition threshold (SAT), and thus were justified in accordance with FAR 13.106- 1(b)(1) as “FAR Part 13 Contracting Officer Determination to Sole Source Proposed Contract Not Exceeding the SAT” (a.k.a. KO Determinations). Since KO Determinations under FAR 13.106-1 do not have the same high documentation standard as FAR Subpart 13.5 J&As, previous KO Determinations did not cite planned actions to remove any barriers to competition.

Therefore, there are no outstanding actions to be completed.

3. Description of Supplies/Services: Doble test equipment is required to meet North American Electric Reliability Corporation (NERC) standard Protection and Control 005 (PRC-005), as well as all South Atlantic Division (SAD) maintenance standards regarding generation equipment testing. Equipment that is to be leased includes M4100 Insulation Analyzer, M4110 Leakage Reactance Interface, M4300 Transport Cart (used to move the M4100), and the MFL Liquid Test Cell and Carrying Case. This equipment will be used to assess the condition of insulation of transformers, breakers, and cables by outputting up to 10kV onto a test subject and producing data such as power factor, leakage current, watt loss, and capacitance. Each test performed by the Doble test equipment is saved into Doble software, Doble Test Assistant (DTA). This software takes the test data and then compares it to data from similar equipment that is stored in a comprehensive Doble database, spanning decades of testing at countless sites.

This lease agreement comes with engineering support in the event test data needs to be reviewed more in depth. The lease agreement also ensures free replacement and next day shipping should the equipment malfunction or fail. Neither of these benefits are available with a direct purchase.

If equipment was purchased instead of leased, SAM and SAS would be responsible for the cost of replacement and/or calibration of the equipment, as well as paying for engineering support each time it is necessary to be used.

The estimated cost of this lease agreement over the 5-year period of performance is $

5. Reason for Authority Cited:

a. Background: Mobile and Savannah Districts have 11 hydropower facilities housing 47 generators combined. They also contain countless transformers (main, station service, neutral, and potential) and breakers (unit, line, station service). Each plant typically has one to two generators/transformers come down for quadrennial or biennial maintenance every year. During these outages, testing must be performed to determine the overall condition and health of the equipment.

The M4100 Insulation Analyzer is used to test transformers, breakers, bus, bushings, cables, oil, and lightning arrestors. Using its high voltage test lead, up to 10kV can be injected into the subject being tested. This, combined with a return and ground lead, generates test data including power factor, leakage current, exciting current, wat loss, and capacitance. Analyzing this data, one is able to determine the condition of the insulation on tested equipment. The test results can then be compared with historical data to trend the direction of the equipment health.

The M4110 Leakage reactance test set is used in tandem with the M4100 to determine reactance of transformers. This data can be used to determine if winding deformation has occurred.

The MFL Liquid Test Cell is a small metal container that is used to test transformer oil. A small amount of oil is drained from the transformer into the test cell. The cell is then connected to the M4100. The M4100 injects 10kV onto the cell. Using the returned test data (power factor and watt loss), the condition of the transformer oil can be determined.

SAM and SAS combined have 47 generators and countless transformers and breakers.

These plants cover Florida, Alabama, Georgia, and South Carolina. In order for engineers and plant personnel to accomplish all testing at each plant during scheduled outages, it is necessary to have two sets of test equipment. Having two sets of equipment would be available to be used for troubleshooting purposes.

b. Justification: There are no known sources other than Doble who can meet the

Government's full requirement for test equipment, to include access required historical test data, engineering support, and a leakage reactance test set. Doble test equipment has been used for over 20 years in these districts. Because of this, a very comprehensive database has been complied in the Doble Test Software (DTA). This database contains historical test data for all equipment at each plant to make an accurate determination of the health of each piece of equipment. Installing a different system will result in increased researching, procuring, and utilizing an alternative brand of test equipment. This would result in additional costs for training and a loss of the use of Doble’s test database.

c. Alternative: An alternative to using Doble Engineering Company to lease the required test equipment is to open and compete the requirement to other companies such as which would have an approximate cost of plus the loss of access to Doble’s global database. While this alternative was considered, r does not meet the Government’s full requirement as they do not offer a leakage reactance test set as required by the scope of work.

(1) A breakdown of the estimated costs are as follows:

i. Leasing two power factor test sets for five years from another brand would cost per year ). The Technical Manager contacted a representative by phone on September 13, 2024, to request a quote for two power factor test dets (Delta 4000) and two leakage reactance test sets. The representative sent a quote via email totaling the previously mentioned amount (Attachment A). The representative also noted that does not currently offer a leakage reactance test set, which is required by this J&A.

ii. The cost of paying for someone to come and train our engineers would be approximately 0. A Request for Quote was requested and received from r for the cost of two r employees to perform training for a week on test equipment and software (Attachment B). Please note that Doble includes five days of training with a lease agreement. Multiple days of training is not offered with a lease agreement and must be purchased at an additional cost.

iii. The approximate cost of our employees attending this training would be

. Per the SAM-HTSC Budget Technician, travel orders for eight engineers to attend a week of training in Mobile, AL conducted in July of 2024 cost $ .

iv. The yearly cost of calibration on alternative test equipment would be

The Technical Manager contacted on August 21, 2024 and requested a cost estimate for calibration of two Delta 4000 test sets. The verbal quote received was per devise for a total of

v. Engineering services are included in the Doble Lease Agreement. This includes 24/7 support on test data analysis, troubleshooting, and equipment issues. equivalent of engineering support, “Priority Access”, is not covered in a lease agreement.

cost as it varies depending on the amount of files to be converted and how they would be configured in a PowerDB database).

Costs notwithstanding, Doble offers a long term lease agreement that includes engineering support, five days of training, access to DTAWeb, no calibration or repair costs, and next day shipping (for replacement equipment). Doble also offers a leakage reactance test set. does not include engineering support or multiple days of training with a lease agreement. Each are at additional cost. also does not offer a leakage reactance test set, which is required by this J&A.

d. Impact: If this J&A is not approved, SAM and SAD, Hydropower, will be forced to implement new test procedures as well as the use of new test software. This would generate a cost for training all field engineers on new test equipment and software.

Additionally, access to Doble’s worldwide test database will no longer be available increasing the risk of failure as described in paragraph c.2.i above.

6. Efforts to Obtain Competition:

a. Effective competition: In accordance with DFARS PGI 206-302-1(d) sources sought W91278214L0030 was published on SAM.gov website (SAM.gov) on July 18, 2024 with a response date of August 2, 2024 for interested parties to respond. No responses were received.

b. Subcontracting competition: A Small Business Subcontracting Plan is not required for this contract in accordance with FAR 19.705-2(c) and FAR 19.702 (a)(1)(i).

7. Actions to Increase Competition: There are no known actions to be taken to increase competition for similar future procurements that would not result in increased project costs, reduced efficiencies, and increased overhead costs from installing an entirely different substation relay and control equipment.

8. Market Research: A sources sought number W9127824L0030 was posted to sam.gov (www.

sam.gov) to determine if any interested parties were available to perform the requirements of this J&A. There were no responses to this sources sought.

9. Interested Sources: The Government posted a sources sought number W9127824L0030 to SAM.gov (www.sam.gov) for market research as discussed in paragraph 6 above. There were no responses to this sources sought. This J&A will also be posted to sam.gov.

10. Other Facts:

a. Procurement history: Records of procuring a lease agreement with Doble for test equipment dates from 2006 to the contract that recently expired in April 2024.

b. Other Facts:

(1) Acquisition Data Available: NA - Technical data packages, specifications, engineering descriptions, statement of work, or purchase descriptions are not available and cannot be developed to allow full and open competition under the circumstances specific to this procurement.

(2) Unusual and Compelling Urgency: NA - FAR 6.302-2 is not the authority cited for this justification

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.

Title: Project Manager

Date: See Signature Signature

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.

Title: Field Engineer

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable based on analysis that includes comparison with the Government Estimate. In accordance with FAR 15.403(b)(1), Certified Cost & Pricing Data will not be required for this action.

Title: Contracting Officer

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

Title: Contracting Officer

Approval Based on the foregoing justification, I hereby approve the procurement of Doble Engineering Company leasing of testing equipment on an other than full and open competition basis pursuant to the authority of FAR 13.501(a) and 41 U.S.C. 1901(a)(2) in the amount of . The approval is subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

Approved By:

Contracting Officer