ER2417_JA_-_Brown_University_FINAL_signed_-_REDACTED2.pdf

U.S. Army Corps of Engineers Humphreys Engineer Center Support

Activity

“Development of Coupled Physicochemical and Biological Systems for In Situ Remediation of

Perfluorinated Chemical and Chlorinated Solvent Groundwater Plumes”

Justification for Other than Full and Open Competition

10 U.S.C. 2304(c)(1), as implemented by the Federal Acquisition Regulations (FAR) 6.302-1(a)(2)(i), “Only One Responsible Source and

No Other Supplies or Services Will Satisfy Agency Requirements”

Estimated Amount: $928,144

Control No.: HEC-18-011

FOR OFFICIAL USE ONLY

1. Contracting Agency: U.S. Army Corps of Engineers (USACE), Humphreys Engineer Center Support Activity (HECSA), 7701 Telegraph Road, Alexandria, Virginia 22315.

2. Description of Action: The purpose of this justification is to obtain approval to award a cost contract to Brown University utilizing other than full and open competition for a research effort to support the Strategic Environmental Research and Development Program (SERDP) project number ER-2714. This proposed contract will be incrementally funded with Research, Development, Test and Evaluation (RDT&E) funds.

3. Description of Supplies/Services: This effort will support research of in situ remediation technologies for treating groundwater plumes contaminated with perfluorinated chemicals and chlorinated solvents at Department of Defense (DoD) sites.

The estimated cost to complete the effort is $928,144 for three years from the date of award

4. Authority Cited: 10 United States Code (U.S.C.) Section 2304, paragraph (c)(1) as implemented by Federal Acquisition Regulation (FAR) 6.302-1(a)(2)(i), “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

5. Reason for Authority Cited: SERDP is the Department of Defense’s (DoD) environmental science and technology program, planned and executed in partnership with the Department of Energy (DoE) and the Environmental Protection Agency (EPA), with participation by numerous other Federal and non-federal organizations. Pursuant to Title 10, U.S.C. Sections 2901-2904, the major focus of SERDP is to address environmental matters of concern to DoD and DOE through support for basic and applied research and development of technologies that can enhance the capabilities of the departments to meet their environmental obligations. SERDP supports environmental research and development activities in government, industry, and academic laboratories in the areas of environmental restoration, munitions response, weapons systems and platforms, and research conservation and climate change.

The intent of the research effort is to develop in situ remediation technologies to treat groundwater plumes containing two specific contaminants: perfluoroalkyl substances (PFAS) and chlorinated ethenes. PFAS contaminations are generally the result of fire fighter training exercises and fire response activities, and chlorinated ethenes contamination generally results from aircraft engine cleaning, paint removal, and degreasing activities. Both contaminants are found frequently at DoD sites, and they present a risk to the drinking water supply of surrounding communities. EPA maintains stringent drinking water standards regarding these types of contaminants, and while remediation technologies have been developed and deployed successfully for certain contaminants over the last two decades, technologies for treating PFAS and chlorinated ethenes contaminants have garnered limited success or practical value.

FOR OFFICIAL USE ONLY

The original proposal was submitted on 08 March 2016 by Tufts University in response to a competitive Broad Agency Announcement (BAA) BAA-16-0001. The research proposal was developed by a principal investigator (PI) considered a leading expert in the field of environmental engineering. A SERDP peer review board conducted a multi-stage review process from March–August 2016 and selected Tufts’ proposal for award. The review and selection process of proposals received in response to BAA-16-0001 resulted in all proposals judged to be of sufficient scientific merit by the peer review board, and determined by the SERDP Environmental Restoration Technical Committee to be of sufficient DoD applicability, were funded and awarded, with the exception of the Tufts proposal.

Prior to contract award to Tufts University, the PI relocated to Brown University.

With the loss of the PI, Tufts University could no longer support this research effort as the prime contractor. On 20 October 2017, Brown University submitted the same research effort proposal, utilizing its facilities and resources to lead the effort as the prime contractor. Brown University’s proposal was reviewed by the SERDP scientific peer review board consistent with the standards established for the initial BAA review and project award and was determined to satisfy the criteria necessary for award.

Replacing the prime contractor caused the research proposal to be resubmitted after the BAA-16-0001 proposal due date. The proposal is not considered a timely response to the BAA announcement; nonetheless, in accordance with FAR 6.302- 1(a)(2)(i), the Government considers the proposal to demonstrate the unique capabilities of Brown University to provide the particular research services, which are not otherwise available from other sources. Brown proposes the same research project under the same PI that demonstrates more than three decades of experience in research related to these types of remediation activities and is uniquely qualified to successfully lead this effort. Brown University will serve as the prime contractor and provide facilities and resources, commensurate with a University of its considerable reputation, and which are more than adequate for successful completion of this project.

Timeline of relevant events:

- On 4 January 2016, Tufts submitted a pre-proposal.

- On 4 February 2016, Acting Executive Director of SERDP, sent a letter to Tufts University and the project’s Principal Investigator, asking for a full proposal

- On 7 March 2016, Tufts submitted a full proposal.

- On 1 December 2016, Acting Director, ESTCP sent a letter notifying Tufts University of funding approval and asked for a revised proposal by 21 December 2016 to resolve minor questions and comments.

- On 21 December 2016, Tufts University submitted a revised proposal.

- In the summer of 2017, the Principal Investigator took a position at Brown University.

FOR OFFICIAL USE ONLY

- On 20 October 2017, Brown University submitted a full proposal.

- On 6 November 2017, the SERDP Environmental Restoration Technical Committee] reviewed the proposal and judged it to be of sufficient scientific merit and sufficient DoD applicability.

6. Efforts to Obtain Competition:

This proposed contract action was synopsized on the Federal Business Opportunities (FBO) website (www.fbo.gov) on 12 June 2018 under W912HQ-18-SN-0016. Interested vendors were given until 28 June 2018 to provide a response. One response was received from a vendor marketing its PFAS monitoring products (not remediation tools/services), and requesting to be put in touch with the project lead for this effort. A technical review of the products was performed, and SERDP found that the vendor would not bring the relevant skillset required for laboratory-based studies on the physical, chemical, and biological processes.

This proposal was originally solicited under BAA-16-0001 using full and open competition. A subcontracting plan in accordance with FAR Subpart 19.7 will be obtained and negotiated prior to contract award to ensure that the prime contractor obtains as much competition as possible in its subcontracting.

7. Actions to Increase Competition:

With the goal of providing increased competitive opportunities for FY19, SERDP will issue a special supplemental BAA, posted for up to ten months, with the intent of identifying ongoing DoD initiatives and avoiding future potential sole source actions.

Each proposal received will undergo the same technical review process as with the regularly scheduled BAAs.

8. Market Research: As mentioned above, the proposed contract action was synopsized as a Notice of Intent to Sole Source on 12 June 2018 for over 15 days, and resulted in no responses. No additional market research has been conducted for the purposes of this contract action.

9. Interested Sources: To date, no other sources have written to express an interest.

10. Other Factors supporting the use of other than full and open competition:

a. Procurement History: This is a new award with no procurement history.

FOR OFFICIAL USE ONLY

APPROVAL

Based on the foregoing justification, I hereby approve the procurement of the SERDP Project number ER-2714 entitled, “Development of Coupled Physicochemical and Biological Systems for In Situ Remediation of Perfluorinated Chemical and Chlorinated Solvent Groundwater Plumes”, in the amount of $928,144, on an other than full and open competition basis, pursuant to the authority of 10 U.S.C. 2304(c)(1), as implemented by the Federal Acquisition Regulations (FAR) 6.302-1(a)(2)(i), subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

JACQUELINE C. WOODSON

Alternate Advocate for Competition w2ct9hd9 Rectangle