Corrosion Prevention & Control (CPC) Acquisition Issues  

by Joseph C. Dean, P.E. for the Director, Corrosion Policy & Oversight (D, CPO) [OUSD (AT&L)]
Updated: 09-26-2017

 

Introduction

Implementation of good CPC practices depends on a successfully executed acquisition process. Overarching acquisition guidance is received from the Federal Acquisition Regulation (FAR), the Defense Federal Acquisition Regulation Supplement (DFARS) and the Defense Acquisition Guide (DAG). The actual procurement process begins with the identification of the requirement and continues to the creation of a statement of work and the associated contract documents and realization of a completed facility contract.

Description

The term "acquisition" means acquiring, by contract with appropriated funds of supplies or services (including construction) by and for the use of the Federal Government through purchase or lease, whether the supplies or services are already in existence or must be created, developed, demonstrated, and evaluated" (FAR 2.101(b)(2). The term "acquisition" throughout this webpage is in reference to facilities. Common to each DOD Component engaged in facilities management is the need to plan, design, construct and sustain those assets. The Facilities Life Cycle (Figure 1) involves elements of Planning and Requirements Definition, Sustainment Restoration and Modernization (SRM) Engineering and Design, Construction and Commissioning, Sustainment, Renovation, Restoration, and or Disposal. All of these steps interact with the defense acquisition program to create a lasting CPC solution.

A flowchart titled Acquisition & the Facilities Life Cycle. Going clockwise, the flowchart starts with Planning & Requirements Definition, SRM Engineering & Design, Construction & Commissioning, Sustainment, Renovation & Restoration or Disposal, and Acquisition Support DB, DBB, Simplified Acquisition, IDIQ, etc..

Figure 1: Flowchart of the Acquisition & the Facilities Life Cycle

Acquisition Overview and Acquisition Strategy Impacts On CPC

Contracting officer support for facility acquisition is essential when obtaining timely resolution of corrosion-related deficiencies. Installations that have in place an array of contract vehicles that are specifically designed to support facilities and infrastructure, especially corrosion prevention and control, are more successful at minimizing the effect of corrosion. Differing acquisition strategies and delivery methods (e.g. Design/Bid/Build (DBB), Design-Build (DB), Simplified Acquisition, Task Order/Indefinite Quantity Job Order Contracts, etc.) should consider and include CPC in their requirements definition, RFP and execution. Information contained on the WBDG and addressed on these pages are good resources to consider and include as the RFP and specifications are developed and executed. Fitting all of the pieces together correctly (See Figure 2) will have a significant impact on the realization of a successful CPC project that is durable and appropriate for life cycle expectations.

A flowchart that displays fitting the pieces together to create a durable and sustainable project that meets requirements. Chart starts with Acquisition Strategy, Technical Selection Factors, Statement of Work, Request for Proposal, Contractor & Designer Qualifications & Experience, Criteria, Design, QA, QC, Cx, and e-OMSI & Turnover.

Figure 2: Fitting the pieces together to create a durable and sustainable project that meets requirements

During a DB acquisition, the request for proposal (RFP) includes a scope of work (project program) and defines the associated performance criteria required to achieve a successful constructed facility. The DB contractor retains the architect-engineer to develop the design documents and subsequently accomplishes the work. Design-build contracts may include corrosion-related requirements within the RFP. The primary contractor has full responsibility for the design and construction of the project or facility, which can expedite project completion. The downside is that the DB contractor will maximize profit and essential decisions related to CPC or other important design features are often a secondary consideration.

A DBB contract begins with a fully designed facility provided by either an architect-engineer firm retained by the government or by an in-house government design team. The successful bidder is awarded the contract to construct the facility according to the government-provided design and specifications. Design-bid-build contracts should address CPC during the design phase, which is executed by the government contracted architect/engineer (A/E). DBB may have a longer lead time for execution, but this allows the greatest opportunity to address corrosion-related requirements. DBB may use government personnel to perform A/E design functions. This helps in the development and retention of in-house CPC capabilities. Specific technical details and technologies are identified during the design process, and design reviews are conducted on the schedule laid out in the contract.

Indefinite delivery, indefinite quantity (IDIQ) contracts are widely acknowledged as a good mechanism for single discipline project work (such as painting, HVAC, roofing, roads, and electrical). Some installation representatives commented during the FICE Study that they have IDIQs developed for each major SRM area. IDIQs allow quick delivery order award (within hours, as opposed to months). These contracts allow for focused repairs resulting from corrosion and the installations are positioned to request specific CPC related coatings and related actions ensuring better and more durable solutions for sustainment.

Installation services (sometimes referred to as base operating support (BOS) contracts may include specific CPC requirements and deliverables, and the contractor must have qualified personnel on staff or must subcontract CPC efforts to qualified personnel. BOS contracts/installation services are widely used across installations because of the need for responsive services.

Military construction projects typically utilize several different acquisition strategies such as Design-Build and Design-Bid-Build to accomplish the work. The project contract documents contain the project scope, performance clauses, and relevant criteria requirements for the designer of record to accomplish the task of preparing the design, plans and construction specifications.

Criteria, Specifications, and Contractor Qualifications

It is important to understand what the FAR clauses are saying and how they can enable the Contract to achieve the desired objective of having a completed project that is durable and meets life cycle objectives including appropriate CPC focus. As contract documents are developed the FAR clauses actually have to be inserted in the contract document. It does not happen by chance, and while many clauses Maybe "automatically" included the customer and the acquisition professional must be knowledgeable enough to make certain that clauses pertinent to the acquisition are included (i.e. buyer beware).

The following FAR Clauses are summarized here:

  • Contractor competency requirements are defined in the FAR Part 9.103(a) "Policy:" "Purchases shall be made from…responsible contractors only."
  • FAR Part 9.104-1 "Contractor Qualifications and associated procedures" and, "have the necessary organization, experience, …technical skills, or the ability to obtain them."
  • FAR Part 9.104.2 "Special Standards" "…the contracting officer shall develop, with the assistance of appropriate specialists, special standards of responsibility."
  • FAR Part 36.601-4: Implementation requires A/E services to be accomplished be a registered engineer or architect including defining services performed under that definition such as "plans and specification."
  • FAR Part 36.602-1: Selection Criteria contractor evaluation should include "professional qualifications, specialized experience and technical competence in type of work required…"
  • FAR Part 53.236-25: "Requirements for Registration of Designers. As prescribed in 36.609-4, insert the following clause: Requirements for Registration of Designers (June 2003) - "Architects or engineers registered to practice in the particular professional field involved in a State, the District of Columbia, or an outlying area of the United States shall prepare or review and approve the design of architectural, structural, mechanical, electrical, civil, or other engineering features of the work."
  • FAR Section 52.236-23 "a) The Contractor shall be responsible for the professional quality, technical accuracy, and the coordination of all designs, drawings, specifications, and other services furnished by the Contractor under this contract. The Contractor shall, without additional compensation, correct or revise any errors or deficiencies in its designs, drawings, specifications, and other services."
  • Section 36.301: Use of Two-Phase Design-Build Selection Procedures includes "(iii) The capability and experience of potential contractors" as a requirement.
  • Section 36.702: Forms for Use in Contracting for Architect-Engineer Services.(Discusses SF 252 to award fixed price contract for A/E services and SF330 Parts I and II requirements to evaluate firms before awarding a contract for architect-engineer services.)
  • As prescribed in 36.505, insert the following clause in solicitations and contracts for construction contracts:
    • Section 52.236-5 -- Material and Workmanship. Material and Workmanship (Apr 1984)
      • "(a) All equipment, material, and articles incorporated into the work covered by this contract shall be new and of the most suitable grade for the purpose intended, unless otherwise specifically provided in this contract. … The Contractor may, at its option, use any equipment, material, article, or process that, in the judgment of the Contracting Officer, is equal to that named in the specifications, unless otherwise specifically provided in this contract."
      • "(c) All work under this contract shall be performed in a skillful and workmanlike manner. The Contracting Officer may require, in writing, that the Contractor remove from the work any employee the Contracting Officer deems incompetent, careless, or otherwise objectionable."
    • The qualifications of the architect-engineer editor to make changes to criteria documents to ensure that the appropriate levels of quality and CPC solutions are required and ultimately incorporated into the construction is an important consideration.
    • The construction contractor as defined in FAR 52.236-5 (see above) is required to provide "All equipment, material, and articles incorporated into the work covered by this contract shall be new and of the most suitable grade for the purpose intended, unless otherwise specifically provided in this contract."

The SF330 submitted by the A/E Firm conveys the level of experience, education and registration details. The A/E in the SF330 is required to establish the level of experience gained that is relative to the new project being acquired.

The criteria listed in the WBDG is based on industry standards that are usually written and maintained by a standards organization, such as the American National Standards Institute (ANSI), ASTM International, the Institute of Electrical and Electronic Engineers (IEEE), National Association of Architectural Metal Manufacturers, and many others. The use of such industry standards ensures uniformity and consistency and cuts down on the cost and time it takes to create new criteria.

UFC's identify the consensus building codes and standards in addition to DoD unique design requirements. UFGS are used to develop the project specifications which delineate the requirements regarding the materials, products, installation procedures and quality aspects involved with execution of the work. It is the responsibility of the designer of record to develop the specification, select the criteria, and edit it to meet the specific acquisition requirement. In the case of corrosion, the desired level of detail associated with the building component (e.g. material selection and grade, protective coatings and paints, cathodic protection, etc.) should be identified. The UFC 1-300-02 requires:

  • that the designer address corrosion related requirements
  • to ensure that the UFGS "Notes to Designers" are inclusive of these requirements
  • addresses inclusion of CPC requirements in the notes to designer when required

From a CPC perspective, the editable nature of the criteria is intended to provide the designer with the flexibility to match the appropriate material, coating, and installation procedure with the environmental conditions that cause corrosion or environmental severity of the project site (see Figure 3).

UFC 1-200-01 DoD Building Code (General Building Requirements) requires the use of UFGS. Designer notes are inset in bold text in the UFGS; the AE is allowed to edit the UFGS to make it consistent with the desired scope. For example:

NOTE: This specification is for an industry standard, 1 Coat Field Applied, 2 Coat Shop Applied,
thick film, coating system that is compliant with
EPA VOC regulations.

A good example that is very specific about required contractor expertise is delineated in the UFC 3-570-01 Cathodic Protection. The UFC provides general & specific design guidance for cathodic protection systems. Key words include (Corrosion, Cathodic Protection, Coating, Pitting, and Galvanic). It is intended to be used in the design and construction of cathodic protection systems for the purpose of mitigation of corrosion of buried or submerged metallic structures. The UFC requires NACE Cathodic Protection and Corrosion Specialist certifications and support. It addresses corrosion related Commissioning (Cx) support.

A good example of a UFGS that addresses qualifications and certifications is UFGS 09 97 13.16 Interior Coating of Welded Steel Water Tanks. Key words include Coating, Corrosion and Rust. The UFGS covers the requirements for polyamide epoxy coating system for interior of newly constructed Navy and Air force water tanks, potable and non-potable, where shop applied coatings are not being considered. It addresses Contractor qualifications and experience (e.g. SSPC QP-5, SSPC C-7, etc.).

A flowchart of The Criteria Process.  The center of the chart reads Design/RFP.  Then on the going around the center it reads: Requirements Core UFC's, Materials & Coating UFGS, UFGS Guide Specifications Format Standard 1-300-02.

Figure 3: The Criteria Process

When deemed appropriate, the UFGS should specifically identify the insertion of certifications, qualifications and experience, providing flexibility to the designer and should leverage the intent of the related UFC. Where corrosion related certifications, qualifications and experience are not mentioned in UFCs, especially for prime building areas (docks, pavements, fire protection, etc.) the risk of designing and constructing a facility that has not included the needed CPC experience and scrutiny that will extend its performance though the desired life cycle is increased. A significant concern related to requiring certifications relates to the perception that competition may be limited and or proprietary.

If additional experience, certifications and qualifications are deemed appropriate in criteria to achieve facility life cycle, durability and sustainability objectives, a possible decision tree might be (see Figure 4):

  • Is this CPC related?
  • Is this a design function or construction procedure?
  • Is there an industry certification?
  • Why is it necessary to require the certification?
    • Requires high degree of skill or experience
    • Quality at risk if done by uncertified personnel
    • Known sustainment problems such as frequent premature failures, high maintenance costs
    • High risk system
    • Life Safety or health concerns
  • What are the costs and impacts of requiring additional certifications and qualifications?
Figure 4: Contract(or) Qualifications, Certifications, Criteria & Standards for CPC

Figure 4: Contract(or) Qualifications, Certifications, Criteria & Standards for CPC

Milcon and SRM CPC Quality Concerns

Successful SRM and MILCON acquisition contracts include quality assurance (government) and quality control (contractor) to ensure that construction is consistent with the contract documents, and includes CPC aspects of project execution. Lack of CPC-trained personnel and available resources directly affects the quality of completed construction. By providing greater CPC awareness for contractors providing MILCON and SRM support at DoD installations a greater chance of extending the facilities' service life can be achieved. The FICE Study team observed that the adherence to criteria in the UFGS and correct UFGS application usually results in CPC being included on projects. While design agents and design teams are knowledgeable of the UFGSs and UFCs, they may be marginally aware of CPC requirements and the benefits of appropriate material selection. Improving design agent CPC awareness will increase the knowledge base and improve corrosion-related decision making.

Including CPC Considerations In Design and Construction

Facility vulnerability and the potential effects of corrosion need to be fully evaluated and understood as a requirement and part of project planning, acquisition (RFP and SOW), design, construction, durability assessment and sustainment phases and activities.

Table 1 is a short list of facility types, utilities, structures, building systems and components with high cost corrosion impacts that require or benefit from careful selection of appropriate CPC features. These Facility Types and Building Components represent potential high-risk CPC sustainment costs for systems and life cycle durability, sustainability and longevity impacts. The effect of corrosion due to the environment both outside and inside facilities can be considerably intensified by the facility type, use and location. In many instances, appropriate CPC features may not be sufficiently covered by standard unit costs and area cost factors. Note that the environment that affects a specific material or system correlates directly to the conditions of the "micro-environment," which is the "local environment" that occurs on the surface of the material or system that it actually experiences.

Table 1. High Risk Facility Types and Building Components for CPC
Facility Type Risk Descriptor Corrosion Stressors Environment Al Severity Mission Impact
Pavements Asphalt binder breakdown, loss of flexibility, cracking & pothole failure, base course & structural failure, concrete reinforcing steel corrosion (spalling) Thermal & Photo Oxidation, Ultra-violet Radiation degradation, Freeze Thaw (Frost Heave), Corrosion of reinforcing steel (Concrete Pavements), Chemical impacts (salt &amp other chemicals), Heat impacts of jet blast Varies based on Environmental Severity Zone For operational pavements such as airfields & critical road infrastructure, loss of mission capability affecting the National Defense. For roads & related pavements, inability to support designed functions creating delays, congestion, disruption.
Waterfront & Coastal Structures Extreme Corrosion exposure, High Risk of structural failure, sea level rise (fixed elevation exposure to high salinity impacts from dramatic variations in sea level) Salt water, dramatic shifts in tides, temperature temperature, moisture, water borne pollutants Varies based on Environmental Severity Zone. Typically, C3: coastal areas with low salinity, C4: coastal areas with moderate salinity, and C5: coastal areas with high salinity. Facility availability, high sustainment costs, reduced life cycle
Wastewater Plants Highly corrosive environment, catastrophic equipment failure, rust, mildew, cathodic protection related corrosion risks (see UFC 3-240-13FN) Water borne corrosive pollutants, temperature, moisture, corrosive chemical reactions, abrasive, pitting, cathodic, mold, mildew, organic growth & reactions "Micro-environment" and based on Environmental Severity Zone Public Health, Environmental Pollution
Interior spaces w/high humidity, plumbing & fixtures Mold, Mildew Humidity, temperature, moisture, poor air circulation, air borne corrosive pollutants "Micro-environment" Health, Moral, Safety
HVAC System Corrosion, air quality, cathodic corrosion, coatings, mold, mildew, disease, humidity control, facility surface and structure deterioration Air borne corrosive pollutants, temperature, moisture, corrosive chemical reactions, abrasive, pitting, cathodic, mold, mildew "Micro-environment" and varies based on Environmental Severity Zone Health, Structural Integrity, Morale, Safety, High Sustainment Cost Impacts, Reduced Life Cycle
Fire Protection System Rust in high risk areas impacting system operation and availability, risk to structure and life safety (See UFC 3-600-01) Moisture, salt water/air, inadequate coatings, pitting, internal corrosion "Micro-environment" and varies based on Environmental Severity Zone Denial of facility availability
Building Envelopes In highly corrosive environment, exterior equipment and system failure (e.g. roof, windows, doors), rust, mildew, weather affects related corrosion risks Humidity, wind, temperature, moisture, corrosive chemical reactions, efflorescence, abrasive, pitting, cathodic, mold, mildew, air borne corrosive pollutants Varies based on Environmental Severity Zone Structural Integrity, Morale, Safety, High Sustainment Cost Impacts, Reduced Life Cycle

Note:

  1. Interior structure impacts will vary in intensity based upon ES area and environmental controls
  2. In areas of high humidity or industrial pollutants HVAC will have to be designed to address the "micro environment" impacts on the system. The cost of management and associated impacts of the "micro environment" are generally costly and, therefore, a significant cost of the total project. Addressing this in initial estimates along with high-level documentation in the 1391 will ensure that the system & components are adequately funded once approved.
  3. In addition to environmental severity, the rate of corrosion can be affected by:
    1. Chemical stresses: increased presence of corrosive atmospheric contaminants due to facility type/use, i.e. pollutants derived from operation of a plant
    2. Mechanical stresses
      1. Atmospheric: abrasive stresses (erosion from wind due to presence of particulates, i.e. sand)
      2. Hydrodynamic: abrasive stresses in water from solid debris or flow/current (i.e. waterfront and/or immersed structures and components)
      3. Structural: stresses on structural materials or components due to strain, compression, elasticity, tensile forces, etc. and/or high temperatures, i.e. stress corrosion cracking
    3. Condensation: can be particularly corrosive in areas where condensation may occur at regular intervals (i.e. cooling pipes), contributes to surface wetness
    4. Increased salinity due to areas where deicing salt is used

A successful commissioning program is critical to achieving good CPC in construction. During turnover from the construction agent to the installation responsible for sustainment, key documents that include information on the built facility (e.g. as-built drawings, material types (coatings, cathodic protection), equipment descriptions and operations, manuals, warranties, etc.) along with commissioning information must be transferred to the SRM manager. This is typically referred to as Operations and Maintenance Support Information "OMSI" and is usually electronic (e-OMSI). This information is key to successful SRM management. UFC 1-300-02 paragraph 202.12.7.2 Operation and Maintenance Manuals discusses this requirement.
Sustainment plans should include as-built conditions included in the electronic Operations and Maintenance Support Information (e-OMSI) UFGS 01 78 24.00 20 and Comprehensive Facility Operation and Maintenance Manual provided by the Construction Agent during facility turnover. SRM Managers should insist on receiving these essential documents along with systems training to best position the sustainment personnel to ensure that life-cycle expectations for the delivered facility is achieved.

Acquisition Best Practices

The following "Best Practices" were provided by the 30 installations that participated in the FICE Study to share their best corrosion prevention and control practices. The list provided below is not endorsed by OSD or the Military Departments, but it is representative of ideas that have worked for individual installation facilities professionals. It is important to note that these best practices may not be consistent with current criteria. It is also important to note that these facilities professionals are doing the best job they can with extremely limited resources. The best practices are location specific and take into consideration environmental severity at that locale.

  • Ensure that budgets and funding allow for appropriate CPC materials and coatings, such that the selected features are life cycle cost effective and the component(s) can reach the intended service life without extensive preventative or corrective maintenance.
  • Ensure that CPC features or requirements are included in project and construction documentation such as the request for proposal, associated designs and criteria documents, and Contractor Quality Control, Quality Assurance and Commissioning Plans regardless of the size and type of procurement
  • Ensure that personnel engaged in CPC decision-making activities, such as acquisition, design, inspection, maintenance, and repair, have appropriate training and qualifications
  • Inconsistencies in the use of the WBDG criteria for design and construction can result in a deficiency to contract for DoD-mandated levels of standardization and quality. This is a potential cost problem that includes questionable identification of and contracting for CPC requirements
  • Consistent with DoD Directive 4270.5 (Military Construction), utilize the CPC criteria and information hosted on the Whole Building Design Guide including UFC, UFGS, Engineering and Construction Bulletins (ECB), and performance technical specifications. If necessary, mark-up guide specifications (e.g., UFGS) with prescriptive CPC requirements
  • Ensure that information on CPC features is included in the project as-built drawings, operation and maintenance documentation, and other related information
  • Use IDIQ contracts for painting, valve replacements, roofing with certified installers, etc. This allows quick contract award within hours
  • Utilize and leverage Contractor Performance Assessment System (CPARS)
  • Contract out water treatment for HVAC and boilers
  • Document lessons learned and feed them into specifications to make further improvements for mechanical systems in the areas of equipment selection and materials. This ensures that the best practices are followed in the next design
  • Installations prefer a centrally managed, multiple-use or multi-purpose contracting vehicle for expediency of project execution
  • Including lead abatement in painting contracts ensures workload will be accomplished more seamlessly
  • CPC requirements are often left to the assigned project manager after the project is approved for inclusion in the Request for Proposal (RFP). Good planning principles encourage planners to make certain that the appropriate CPC wording is included in project documentation and associated estimates and mission impact statements
  • CPC should be considered in the initial design or planning stages; however, how corrosion-related requirements are addressed depends on the type of contract vehicle used
  • Quality control is the responsibility of the contractor, and quality assurance is the responsibility of the government. QC plans do not address every element of construction, and some bases are not aware of QA/QC plans that specifically address corrosion requirements
  • Most constructability reviews are conducted by contract managers or public works staff members. The general opinion of installation representatives is that QA and QC is lacking. Specifically, it was noted that contractors do not have the incentive to ensure good QC, and the government does not always have adequately trained personnel to perform effective QA related to CPC
  • DB, DBB, and IDIQ contracts do not include CPC technical selection factors in contract source selection
  • Many installations feel the best value contractor is rarely selected; most contracts are being awarded as "lowest cost, technically acceptable." In addition, not all technical disciplines are represented during technical evaluation boards so some key requirements are missed in the evaluation. Consequently, design solutions may drive higher CPC lifecycle costs
  • The contracts group must be familiar with facilities acquisition. Supply type functions (purchasing paper, parts, etc.) and the more sophisticated contract actions of DB, DBB, and IDIQ contracting are addressed by separate sections of the FAR; each requires the support of a contracting officer familiar with the specific process. Contract support on some bases was provided by supply contracting offices. Their lack of F&I contracting knowledge impeded SRM progress, drove up costs, and negatively affected mission support
  • Contract requirements of open competition do not allow intelligent buying for purposes of configuration control and standardization (e.g., multiple air conditioning units from different vendors)
  • The best-performing contracting groups, from a CPC perspective, are staffed as part of the F&I organization, thus, ensuring contracting personnel are knowledgeable regarding facilities construction and maintenance as well as corrosion. Achieving desirable CPC outcomes is more of a challenge at installations where contracting personnel are unfamiliar with facilities or installations
  • Some installations indicated that mandatory contracting targets, such as contract laws and mandated small business set-aside programs (8[a], HUBZone, SDVOSB, etc.), hinder their ability to obtain the best-qualified CPC contractor and solution
  • For design-build projects, the contractor has greater flexibility in using newer, better technologies to meet the performance requirements of the contract. In many cases, however, the contractors shy away from offering CPC technologies that would exceed the minimum performance requirements-even if the technologies would provide a lifecycle cost advantage-because these technologies cost more initially and increase project costs, putting the contractor at a competitive disadvantage

Relevant Codes and Standards

Department of Defense

Unified Facilities Criteria (UFC)

Additional Resources

WBDG

Other

Federal Facility Criteria: 
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