80KSC025F0008 - NESS Limited Sources Justification (LSJ)_For Posting.pdf

Rev.:10/2025

Authority Cited and Rationale:

FAR 8.405- compelling need exists, and following normal procedures would result in unacceptable delays.

FAR 8.405- (1)(B). Only one source is capable of providing the supplies or services highly specialized.

FAR 8.405- a)(1)(C). In the interest of economy and efficiency, the new work is a logical follow-on to an original GSA FSS order provided that the original order was placed in accordance with the applicable GSA FSS ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

FAR 8.405- (b), Items Peculiar to One Manufacturer. An item peculiar to one manufacturer can be a particular brand name, product, or a feature of a product, peculiar to one manufacturer. A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer.

Rationale:

demonstrating why the Government has an urgent and compelling need that cannot be met if normal ordering procedures are followed, and why restricting consideration under FAR

Pricing Discrepancy Originating from RFQ Structure discrepancy arose from how the Government presented information in the pricing spreadsheet and reasonably interpreted that information. The Government inserted a “plug” amount for hazardous waste (HW) disposal into the “Estimated Labor Price” column of the Time-and-Materials (T&M) tab rather than in the “Estimated Materials Cost” column.

Because the amount was placed in the labor column, understood the plugs to represent estimated labor hours needed to perform HW disposal activities. As a result of that interpretation, the combined cost of HW labor and disposal.

cover only HW materials and disposal, while labor for HW-related tasks was expected to be priced under the corresponding Performance Work Statement (PWS) section tabs. This created a significant variance between expected pricing and vendor-submitted pricing. The value incorporated in this modification reflects the remaining

HW disposal, Correcting this pricing discrepancy is not a change in scope; rather, it realigns the order value with the performance the Government originally envisioned during the the ceiling ensures the contract accurately reflects the level of effort that was always unfunded work.

Continuous Readiness Requirement for Emergency Large Spill Response SSC must maintain continuous, immediate, and fully compliant emergency response capability nvironmental contamination, protect personnel, and avoid regulatory violations. Because spills can occur without warning, SSC cannot rely on normal ordering timelines or competition; any delay in activating spill-response resources—whether due to contract transition, onboarding, training, or establishing funding—would create unacceptable operational and environmental risks.

The incumbent contractor already provides an integrated spill-response structure that includes locally pre-hazardous waste environment. This established readiness posture is embedded in current operations and enables immediate mobilization when a spill occurs. Their personnel are fully

—activities that cannot occur cy event.

Additionally, the local subcontractor supporting spill response cannot mobilize without pre-authorized contractual funding. Emergency response depends on contract ceiling being ith large spill events. Without this pre-funded capacity, response would be delayed while contractual authority is established.

For these reasons, maintaining pre-positioned, fully ready emergency spill-response capability constitutes an urgent and compelling need. The nature of large spill events, combined with the continuous readiness and is necessary to avoid unacceptable delays.

Additional Training Requirement for Hazardous Materials Management System (HMMS)

Government-designated Hazardous Materials Management System (HMMS). This training is necessary for ongoing compliance, proper documentation of hazardous waste activities, and incumbent, is the only logical source to receive such training under the current order, as they perform all ongoing hazardous waste management and spill response functions for SSC.

The combination of (1) the need to correct a Government-created pricing discrepancy, (2) the incumbent workforce on the new HMMS system, establishes that only Tetra Tech, Inc. can meet nts without causing delays, operational risks, or environmental and regulatory exposure.

Determination by the contracting officer that the order represents the best value consistent with FAR 8.404(d):

Comparison to Previously Proposed and Accepted Rates The labor categories and corresponding fully burdened hourly rates included in this modification align with the rates originally proposed and accepted under Order No. 80KSC025F0008. No increases to the underlying schedule labor rates were proposed. Because the current order already reflects competition for the basic BPA and the rates remain consistent with the established schedule pricing, this comparison supports a determination that the labor pricing is fair and reasonable.

Reasonableness of the Emergency Large Spill Response Surge Funding The $ per option period allocated for emergency large spill response represents a reasonable level of funding necessary to ensure immediate availability of specialized personnel ost ranges at SSC and other NASA centers with similar hazardous material profiles. Maintaining this ceiling amount der the NESS program. Based on these considerations, the amount represents a prudent and reasonable surge allowance.

Verification of Travel Costs in Accordance With Federal Travel Regulations (FTR) the travel pricing is supported by established regulatory cost ceilings and is therefore fair and reasonable.

process. The revised funding level properly aligns the contract value with the actual level of

Government pays a reasonable price for the full scope of work and prevents the contractor from performing unfunded labor.

Based on the above evaluation, the total price of the modification, $ is determined to critical nature of hazardous waste activities, the need for uninterrupted emergency response capability, and the correction of the discrepancy affecting labor and disposal pricing. The historical spill response cost ranges, and the actual level of effort necessary to fulfill the Accordingly, issuance of this modification represents the best value to the

Government.

Market Research:

The Government reviewed multiple GSA resources, including GSA Advantage!, GSA eLibrary, and GSA eBuy, under SIN 541330ENG and the applicable NAICS code, to identify vendors offering hazardous waste management and

These searches confirmed that although multiple Federal Supply Schedule contractors list environmental or engineering services under the relevant SIN, the specialized scope, support hazardous waste operations and emergency spill response at SSC significantly limit the pool of uity of hazardous waste labor support comparable to that provided by the incumbent under the NESS BPA.

training, and familiarization with SSC facilities and hazardous waste streams—steps that would introduce operational risk and unacceptable delays during an emergency event. Bringing on another vendor would further duplicate effort already included within the scope of the current order.

Based on this research, the Government concluded that transitioning to another vendor would maintain continuous, around-the-clock hazardous-waste and emergency spill-response readiness.

Other Facts:

N/A

A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made:

The Agency will continue to examine the market in the future for alternative solutions or new