SS_Justification_Redacted_1.docx

Date: July 21, 2023

SOLE SOURCE JUSTIFICATION UNDER SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS IN ACCORDANCE WITH FEDERAL ACQUISITION REGULATION (FAR) 13.5

On the basis of the following justification, I, as the Contracting Officer approval authority, hereby approve the use of a sole source proposed contractual action pursuant to the authority 41 U.S.C. 1901 or 41 U.S.C. 1903.

Procurement Request Number: PR-R6-23-00064

1. Identification of the agency and contracting activity, and specific identification of the document as a “Sole Source Justification Under Simplified Procedures for Certain Commercial Items (FAR Subpart 13.5)” The Office of Acquisitions for Region 6, Rayna Brown, Contracting Officer, proposes to enter into a sole source contract with Syft Technologies under simplified procedures for certain commercial items included in FAR subpart 13.5.

2. The nature and/or description of the action being approved, i.e., sole source under procedures for certain commercial items in accordance with FAR 13.5.

EPA Region 6’s Air and Radiation Division (ARD) has proposed purchasing two mobile monitoring spectrometer units to provide both real-time air monitoring screening and analysis for volatile organic compounds (VOCs) in Environmental Justice (EJ) areas. The mobile unit will be used to conduct real-time mobile ambient air VOC monitoring in neighborhoods near industrial facilities. Many of the intended monitoring locations are categorized as being EJ communities as they are above the 80th percentile for various EJ Indices. Funding for this monitoring is detailed in the American Rescue Plan (ARP).

Under ARP, EPA Regions 6 and 5 have proposed similar mobile monitoring mass spectrometer units will be housed within vehicles that are specifically built to monitor ambient air in these EJ communities. Both EPA Regional Offices have drafted requirements and plans for the customization of vehicles to accommodate the spacing, power, venting, and analytical requirements for the SYFT 200 VOICE Ultra Spectrometers. Region 6 will be leading the procurements for the purchase of two (2) instruments, one for each Region, that will be incorporated into these mobile monitoring units.

Currently, ambient air analysis of VOCs suffers from significant limitations (e.g., time-intensive analyses that do not provide results for up to 60 days) and/or limited VOC detection capabilities in the field (e.g., Region 5’s current mobile monitoring unit can only measure benzene). Recent advances in real-time VOC monitoring technology provide the ability to measure VOCs with detection limits comparable to laboratory analyses and provide capabilities to measure many Note: The i8 Tracer Model is an update to SYFT 200 Voice Ultra Spectrometer throughout the document

VOCs simultaneously. Specifically, technological advances in the use of a selected ion flow tube mass spectrometer (SIFT-MS) provide the capability to measure many VOCs at once with the ability to differentiate compounds that have the same molecular mass (e.g., acetaldehyde and ethylene oxide based on their unique ion chemistries).

The SYFT VOICE 200 Ultra new technology that greatly decrease analytical time for VOC monitoring. This instrumentation could expand EPA’s mobile lab capabilities to include analyte difficult to analyze using chromatography such as ammonia, formaldehyde, sulfur dioxide. In addition, the SYFT VOICE200 Ultra system does not require a multi-point calibration curve for quantitation and uses known reaction equations and constants. Instead of a full multi-point calibration curve, a continuing and independent calibration check is performed to verify the instrument is operating properly. Calibration tests on the SYFT VOICE200 Ultra requires only a few minutes. The reduced use of calibration gases could also result in a cost savings as compared to other analytical ambient air methods used by EPA laboratories. Currently, EPA labs purchases TO-15 calibration gases for ~ $5,500 per bottle, and the field’s cost for mobile lab calibration gases are $15,000. The bottle of calibration gas to support the SYFT VOICE200 Ultra is $2,780 and will last approximately a year. External calibration gases can be used to further increase the accuracy of the SYFT VOICE200 Ultra but is only optional.

The SYFT VOICE 200 Ultra would also have applications for stationary field deployment. Currently, field personnel in many EPA Regions often use handheld photo ionization detector (PID) sensors for sample screening purposes, however, PIDs respond to a broad range of organic compounds. Deployment of the SYFT VOICE 200 Ultra in field projects would allow for quantification and identification volatile organic compounds and inorganic gases present in the air or container headspace. Knowledge of the specific compounds and concentrations would increase field personnel safety guiding personal protective equipment selection and would allow the lab to better target analyses for collected samples.

The SYFT VOICE 200 Ultra also presents a unique opportunity to upgrade other analytical capabilities in Region 5 such as Geospatial Measurement of Air Pollution (GMAP). Currently, GMAP can identify and quantitate only a few specific compounds, e.g., BTEX, methane, and a few others. Integrating the SYFT VOICE 200 Ultra as an auxiliary field analytical instrument in the mobile laboratory systems, in addition to GMAP, would allow the field personnel to identify and quantitate 1000+ compounds, enhancing EPA’s value on inspections of chemical and petro- chemical manufacturers.

The ability to identify and quantitate a large library of compounds also creates opportunities for emergency response and Superfund site support where spills, leaks, and emissions of volatile organic compounds or inorganic gases are involved. The SYFT VOICE 200 Ultra’s fast analysis time could allow for efficient production of data in emergency situations, as well as high volume analysis needed to support the ARP projects.

The contemplated contract type is Fixed price with labor hour categories and fixed price rates.

Developed by Virtual Acquisition Office™ for federal government use and customization.

3. A description of the supplies and/or services required, including the delivery schedule and/or the period of performance (inclusive of all option periods), and the estimated dollar value of the acquisition.

The requirement consists of two SYFT Voice 200 ion flow tube mass ultra-spectrometer instruments and two years of preventative maintenance services.

The total estimated dollar value is $866,881.30 .

4. The statutory authority permitting sole source.

The cited authority is in accordance with FAR 13.501(a)(1)(ii) for simplified procedures for certain commercial items under 41 U.S.C. 1901 or the authority of 41 U.S.C. 1903.

5. A statement demonstrating the unique qualifications of the proposed contractor or the nature of the action requiring use of the authority noted in number 4.

The prospective contractor, Syft Technologies, has unique qualifications and/or specialized capabilities or expertise not prevalent in the marketplace. This is supported based on the market research yielding no interested Contractors responding to the Request for Information.

SYFT is the original equipment manufacturer (OEM) of this system. The ionization source of the Voice 200 Ultra is dual polarity. Positive reagent ions include H3O+, NO+, and O2+. Negative reagent ions include O-, O2-, OH-, NO2-, and NO3-. Instruments from other vendors are not capable of generating all these reagent ions. Further, the Voice200 Ultra creates all these ions from ambient air. The Voice is also capable of switching between reagent ions quickly to facilitate quantitation of a large (1000+) library of compounds quickly. Parallel quantitation of the same analyte is an important quality check to ensure the same values are observed for both reagent ions.

The faster measurement response rate for compounds at the higher endo the mass range greater than 120 m/z is required for future field deployment applications of this instrument. While instruments from other vendors offer similar measurement rates, only the SYFT Voice 200 allows for switching reagent ions and maintaining that rate. The ability to perform ~1 Hz measurements across all available ions is vitally important to field deployment applications.

6. A description of efforts made to ensure offers/quotes are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized in FEDBIZOPPS (as required by FAR 5.2) and, if not, which exception under 5.202 applies.

The requirement was publicized by posting a Request for Information through GSA-Ebuy, Fed Connect and SAM.gov resulting in no interested Contractor responses. Additionally, a Notice of Intent will be publicized through Fed Connect and SAM.gov following OSDBU package approval.

7. The anticipated dollar value of the proposed acquisition, including options if applicable, and a determination by the contracting officer that the anticipated cost to the government will be fair and reasonable. [Note: dollar amounts may not exceed statutory limitations for use of the simplified procedures under FAR 13.5.] The contracting officer determines that the anticipated prices will be fair and reasonable based on price reasonableness based on comparison to the independent government estimate in accordance with (FAR 13.106-3(a)(2)(vi)).

8. A description of the market research conducted and the results or the reason market research was not conducted.

Market research required posting through GSA-Ebuy, Fed Connect and SAM.gov with anticipation of collecting and analyzing product/service information on the technical capabilities and prices/costs within the marketplace to satisfy the agency needs.

Based on the market research conducted thus far, noted above, there is potentially only one contractor that can fulfill the agency’s needs.

9. Any other facts supporting the use of sole source.

The Program Management Office research was conducted into other real-time mass spectrometers, including proton transfer reaction mass spectrometers (PTR-MS). Other proton transfer reaction mass spectrometers are available from companies such as Ion icon and Aerodyne, however none of these vendors offer as many chemical ionization agents compared to SYFT. Further, SYFT creates all of their chemical ionization agents from ambient air, compared to other vendors which require additional chemical supplies to create various chemical ionization agents. An instrument which requires additional chemical to create reagent ions would not meet the criteria to utilize this instrument for possible field measurements.

10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

Syft Technologies, Inc. was listed as a potential source capable of fulfilling this requirement that expressed an interest in the acquisition on the market research report submitted by the Program Office.

11. A statement of any actions the agency will take to remove or overcome any future barriers to competition.

This selection of vendor is not meant to restrict competition, but to enhance our green buying power. When we are selecting products and vendors, we look for performance, capability and adherence to the various EPA policy and executive orders mandated, thus reducing our environmental footprint as well as meeting the precise needs of a productive environmental laboratory.

Certification

Acquisition Initiator:

I certify that the facts and representations under my cognizance that are included in this justification and that form a basis for this justification are complete and accurate.

SONJA JOHNSON

Digitally signed by SONJA JOHNSON Date: 2023.08.09 13:47:48 -05'00'

Signature Date

Contracting Officer:

I certify that this justification is accurate and complete to the best of my knowledge and belief.

8/4/2023 MEGAN WALLACE WALLACE

Digitally signed by MEGAN

Signature Date

Reviews and Approvals Program Senior Official (or designee):

I certify that the facts and representations under my cognizance that are included in this justification and that form a basis for this justification are complete and accurate.

CLARENCE JACKSON

Digitally signed by CLARENCE JACKSON Date: 2023.08.09 14:18:13 -05'00'

Signature Date

Activity Advocate for Competition (if > $700,000 and < $13,500,000):

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Since this justification does not exceed $13.5 million, this review serves as approval.

Digitally signed by JENNIFER CRANFORD Date: 2023.08.10 13:48:38 -04'00'JENNIFER CRANFORD

Signature Date