A.02.05 Brand Name James Walker Seals Redacted.pdf

Control Number: 24-028

BRAND NAME DETERMINATION

Far Subpart 13.106-1(b)

1.0 CONTRACTING AGENCY: US Army Corps of Engineers (USACE), Walla Walla District, (CENWW-CT) 201 North 3rd Ave, Walla Walla, WA 99362

2.0 DESCRIPTION OF THE ACTION: The U.S. Army Corps of Engineers, Lower Granite Dam, 885 Almota Ferry Rd., Pomeroy, WA 99347 has a requirement for brand name James Walker North America, commercial item, off the shelf, Back-to-Back Shallex Turbine Blade Seals, installation instructions, and drawings. These seals are designed for the Baldwin Lima Hamilton (B-L-H) Kaplan Turbine Runners, Units 1 - 3, on Lower Granite Lock and Dam.

3.0 DESCRIPTION OF THE SERVICES/SUPPLIES: Approval is being requested for a new firm-fixed-price, brand name, purchase order for the delivery of “James Walker Turbine Blade Seals”. Each turbine has six blades and Lower Granite requires an additional spare seal stack for each turbine family. These seals shall be a direct replacement to OEM seals, requiring no changes to fit, form, or function of the seal box or mechanical hardware. The estimated value of this procurement .

4.0 AUTHORITY CITED:

a. FAR 13.106-1(b) Soliciting from a single source. (1) For purchases not exceeding the simplified acquisition threshold. (i) Contracting officers may solicit from one source if the contracting officer determines that the circumstances of the contract action deem only one source reasonably available (e.g., urgency, exclusive licensing agreements, brand-name, or industrial mobilization).

b. FAR 11.105(a)(1), Items Particular to One Manufacturer. The particular brand name, product, or feature is essential to the Government ' s requirements, and market research indicates other companies ' similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency' s needs.

5.0 REASON FOR AUTHORITY CITED:

A. JUSTIFICATION: Lower Granite Lock and Dam is required to have one complete set of seals on hand for each variety of turbine due to the possibility of seal failure at any time. Such a seal failure would force a generating unit out of service for the duration of an emergency supply contract solicitation and award. The precise size of the blade seals is not a quality which can be varied and must be ensured through precise machine processes. Lower Granite staff is aware of three brands of blade seals that vendors consistently source for blade seal solicitations:

(1) James Walker North America: The soft durometer of the James Walker product is ideal for confined access and eliminates the challenges of the “rock hard” product.

Furthermore, James Walker company is an ISO 9001 certified company with a stringent quality control program. The unique quality control program of James Walker produces a Back-to-Back Blade Seal known to consistently work at Lower Granite, Little Goose, and Lower Monumental Dams. The Type 3 seals provide the strength and rigidity needed to compress and expand the softer inner chevrons. These flexible NM59-74/80 expand and create the seal needed to consistently prevent oil leakage.

B. IMPACT: James Walker brand blade seals are the only brand that provides the tight seal necessary to satisfy current environmental regulations at Lower Granite Lock and Dam.

If alternative seals are purchased and fail in service, the Agency will be exposed to potential Clean Water Act violations and cause environmental damages. The Agency would also incur added time and money due to lost power generation while the turbine generator is taken out of service for another seal replacement.

This estimated loss value can as much as double if the necessary duty cycle of the materials to repair this machine is unacceptable. Having a Unit out of service also has a large fish passage impact and creates a large negative impact on adult fish passage. If Lower Granite cannot purchase functional seals, then the turbine hub will need to be drained of oil and the turbine blades fixed in place. The Kaplan runner would lose the valuable flexibility that an adjustable unit offers. When the runner is fully functional, operators can change the angle of the turbine blades to allow them to meet the regions fluctuating power requirements and maximize operational efficiency. With the blades fixed in place the Kaplan runner is no longer fully functional.

C. ALTERNATIVES: As discussed previously, the government has only three brand options for this application. This Project has used each Brand of products in this application with varying levels of success, difficulty, and overall cost of installation. As stated, labor cost, loss of production and negative environmental impacts are costly to the US Army Corps of Engineers. , James Walker seals have proven to work and are best to meet our current needs.

6.0 DETERMINATION OF FAIR AND REASONABLE COSTS: Price competition should result in a fair and reasonable price; however, no contract will be awarded unless the price is determined fair and reasonable.

7.0 EFFORTS TO OBTAIN COMPETITION: It is anticipated that there are multiple distributors of the James Walker blade seals. See Section 8.0 Market Research.

8.0 MARKET RESEARCH: Market research was conducted in accordance with FAR Part 10, and indicates other companies’ have similar blade seals, but they do not meet, or cannot be modified to meet the agency’s needs. Previous contract purchases for James Walker brand names are W912EF: 21P0065, 21P0060, 21P0051.

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/Title: Amanda J. Sparks / Signature:

Contract Performance Specialist

I certify that the information supporting this brand name determination is accurate and complete to the best of my knowledge based on the supporting data provided by technical or requirements personnel.

Prepared by: Alan Inglis Title: Contract Specialist Signature:

DETERMINATION: In accordance with the authority of 10 U.S.C. 3204(e), as implemented by FAR 13.106-1 (b) and based upon the foregoing, I hereby determine that a brand name procurement is authorized and is in the best interest of the Government.

Reviewed for legal sufficiency: Michaela Murdock Title: Deputy District Counsel Signature: _

Approved by: Brooke Moore Title: Contracting Officer Signature: