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DEPARTMENT OF THE NAVY

PEARL HARBOR NAVAL SHIPYARD

AND INTERMEDIATE MAINTENANCE FACILITY

667 SAFEGUARD STREET, SUITE 100

JBPHH HAWAII 96860-5033

J&A No. 026167

Code: 400
P.R. Number: TBD

JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity

The Naval Sea Systems Command, Pearl Harbor Naval Shipyard and Intermediate Maintenance Facility (PHNSY & IMF) Contracts Division C400.
2. Description of the Action Being Approved
Award of a contract on a sole source basis for repair actions to a Virginia-class submarine’s No. 1 & No.2 CO2 Scrubbers.
3. Description of Supplies/Services.
a. Removal, refurbishment and re-installation of No.1 & No.2 CO2 scrubbers onboard a Virginia-class submarine. Work was identified by the project team and deemed to be mandatory by Engineering and Planning Department (EPD). b. The total estimated dollar value: $565,000.00
c. Funding: FY27, O&MN
d. Period of Performance: 19 OCT 2026 – 31 MAY 2028
The Government’s minimum needs have been verified by the certifying technical and requirements personnel.
4. Statutory Authority Permitting Other Than Full and Open Competition ‫ ܈‬10 U.S.C. 3204(a)(1), Only one responsible source and no other supplies or services will satisfy agency requirements.
տ 10 U.S.C. 3204(a)(2), Unusual and compelling urgency. տ 10 U.S.C. 3204(a)(3), Industrial mobilization; engineering, developmental, or research capability; or expert services.
տ 10 U.S.C. 3204(a)(4), International agreement.
տ 10 U.S.C. 3204(a)(5), Authorized or required by statute.

PHNSY&IMF Code 410 – Contracting Department
Annex 1 (NMCARS Change 26-04)

08/2026

տ 10 U.S.C. 3204(a)(6), National Security.
5. Rationale Justifying Use of Cited Statutory Authority Per Engineering Planning Department (EPD), Cepeda is the Original Equipment Manufacturer (OEM) of the CO2 scrubber systems deployed on 774 Virginia-Class submarines. Cepeda has designed, manufactured, tested, serviced, and refurbished the CO2 scrubber system. Cepeda owns the drawings, and proprietary procedures and equipment necessary to complete the required removal, refurbishment and re-installation of the units. Cepeda has not shared their drawings or proprietary equipment and procedures with any entity, including the Government. Because Cepeda does not share any of the drawings, proprietary equipment or procedures necessary to complete this work, they do not certify or authorize any third-party companies/personnel to work on the scrubbers system. As a result,

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