LimitedSourcesJustification-DE-DT0004141_8-25-14_SIGNED.pdf

DE-DT0004140 Page 1

LIMITED SOURCES JUSTIFICATION

NATIONAL NUCLEAR SECURITY ADMINISTRATION

OFFICE OF THE ASSOCIATE ADMINISTRATOR FOR INFRASTRUCTURE AND

OPERATIONS

OFFICE OF QUALITY MANAGEMENT

GS-10F-0249K/DE-DT0004140

August 25, 2014

I. AGENCY IDENTITY AND CONTRACTING OFFICE

The Office of Quality Management (NA-00-70) within the Office of the Associate Administrator for Infrastructure and Operations (NA-00) of the U.S. Department of Energy (DOE), National Nuclear Security Administration (NNSA) intends to extend and contract for additional ISO 9001:2008 technical advisory services under its current Task Order GS-10F-0249K/DE- DT0004140 with HW&W, Inc. The contracting activity is the NNSA Non-M&O Contracting Operations Division.

II. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

This will result in a modification to extend HW&W’s Task Order DE-DT0004140 until February 5, 2016 and increase the Task Order ceiling by $929,556.27. The current Task Order was competed amongst all General Services Administration (GSA) Mission Oriented Business Integrated Services (MOBIS) Schedule Holders and was awarded on August 3, 2012 at a value of $375,144.08This Task Order has undergone one Task Order modification to raise the ceiling by $633,613.40 to accommodate an increased level of effort required to meet NNSA’s ISO 9001 objectives. The Task Order is fully funded up to its current ceiling of $1,008,757.48. NA-00-70 now requires an extension of this Task Order until February 5, 2016, which will result in a $929,556.27 increase in the total estimated value, raising the Task Order ceiling to $1,938,313.75.

III. DESCRIPTION OF SUPPLIES AND/OR SERVICES

In order to ensure continuous improvement in executing vital roles and responsibilities, the NNSA has begun implementing a management system that complies with ISO 9001:2008, Quality Management Systems, as a means of implementing DOE O 414.1D, Quality Assurance and aims to achieve and maintain ISO 9001:2008 certification. NNSA has initiated the ISO 9001:2008 implementation process and HW&W has provided technical advisory and assistance to NNSA federal employees in the implementation of the ISO 9001:2008 compliant management system across NNSA, focusing on six key ISO 9001:2008 requirements areas necessary for certification: Control of Documents; Control of Records; Internal Audits; Control of Nonconforming Product; Corrective Action; and Preventive Action. This includes support to the following major activities:

Requirements Analysis/Gap Analysis of existing processes/procedures against the ISO 9001:2008 Standard;

Development of Quality Management System Plan;

Development and implementation of new or revised documentation;

Training of affected staff on new documentation/requirements;

Conduct internal audit of the resultant management system and develop and implement corrective action to resolve findings and deficiencies;

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Conduct Senior Management self assessment of the management system and develop and implement corrective action to resolve findings and deficiencies;

Conduct of pre-assessment audit by contracted ISO 9001:2008 Registrar and development and implementation of corrective action to resolve findings and deficiencies; and

Conduct of final certification audit by contracted ISO 9001:2008 Registrar.

IV. LIMITED SOURCES AUTHORITY

The authority permitting limited sources as implemented by the Federal Acquisition Regulation (FAR) is Subpart 8.405-6 (a)(1)(i)(C), which allows for restricting competition, in the interest of economy and efficiency, if the new work is a logical follow-on to an original order placed in accordance with applicable Federal Supply Schedule ordering procedures.

V. JUSTIFICATION FOR USING THE LIMITED SOURCES AUTHORITY

Initial issuance of Task Order DE-DT0004140 was based on the premise that the ISO Implementation Project would be largely conducted by a team comprised of approximately 15 federal employees and that the support required of the contractor would be limited. Due to unanticipated budget constraints, the intended federal staff judged necessary to support the project were never assigned to perform the work or to staff the office in charge of the ISO Implementation. The absence of federal employee support necessitated the use of increased contractor tasking to enable successful completion of the project milestones and as a result NA- 00-70 required more hours for years one and two than originally anticipated. This level of effort is expected to continue through the third year of performance of this Task Order. Moreover, NNSA organizational restructuring and other NNSA corporate management challenges placed additional technical support demands upon the contractors. NA-00-70 therefore requires a fourth year of support from HW&W to obtain NNSA’s ISO 9001 objectives. Below is a summary of original hours estimated, the actual hours performed, and the estimated hours for the third and fourth year of performance:

Government’s Original

Hours Estimates for PWS

Subtasks 3.1-3.5

Actual Hours Performed by

HW&W to Support PWS

Subtasks 3.1-.35

Delta

Year 1 1152 2021 869

Year

2* 768 3,447.75* 2937

Year

3* 1028 3,052 0

Year

3+** 1028** 4,069 0

Total 1920 12,589 10,669

*Hours in “Actual Hours” column for year two and three are estimated and not actual yet, since year two does not end until August 5, 2014 and year three does not end until August 5, 2015. Task Order will be extended until February 5, 2016.

HW&W has been supporting NNSA’s ISO 9001 implementation under its existing Task Order for approximately two years. The knowledge and experience obtained by HW&W specific to NNSA and its component organizations, business processes and procedures over the past two years cannot be replicated by any other firm. Additionally, HW&W has developed the necessary

DE-DT0004140 Page 3 relationships, rapport, and trust of the NNSA federal workforce and management team required to ensure implementation success. HW&W has both the NNSA-specific experience and stable of qualified personnel at its disposal to seamlessly increase its level of support, without any learning curve or delays. The use of any other firm at this point in the project and the associated lead time for new personnel to learn the organization and its processes and procedures, and to establish necessary relationships and rapport would cause unacceptable delays, duplication of effort and increased costs, and place NNSA at risk of failing to achieve ISO registration, meeting its requirements under DOE 414.1D, Quality Assurance, to have such a management system, and meeting its commitment to Congress to implement an ISO compliant management system. Based on the level of support that will be required, an additional $929,556.27 in ceiling is needed to fund this Task Order through February 5, 2016.

VI. CONTRACTING OFFICER DETERMINATION OF BEST VALUE

The contracting officer has determined after considering the level of effort and the mix of skills available for the tasks needed, that the proposed action represents a reasonable total price and will be the best value for the Department consistent with FAR 8.404(d). This action represents the best value to the Government in accordance with FAR 8.405-6 (a)(1)(i)(C) in that the work is a logical follow-on the original Task Order GS-10F-0249K/DE-DT0004140 placed on August 3, 2012 and was not previously issued under sole source or limited sources procedures. In addition, HW&W’s quote in response to the solicitation for the original requirement was chosen as the best value to the Government.

VII. MARKET RESEARCH

Additional market research was not conducted for this action for the following reasons: the contractor’s performance currently exceeds the Government’s expectations; the best value determination from the previous solicitation is still relevant. HW&W is the single contractor capable of executing the work within the timeframe required, with minimal learning curve, lead time and associated costs.

VIII. OTHER FACTS

Any savings the Government could derive from a competitive procurement will not offset the costs and inefficiencies associated with the operational complexities of integrating multiple federal prime contracts to provide technical and advisory assistance technical advisory and assistance to NNSA federal staff in the implementation of the ISO 9001:2008 compliant management system across NNSA. HW&W is currently performing this work and HW&W was selected as the best value Government. Initial issuance of Task Order DE-DT0004140 was based on the premise that the ISO Implementation Project would be largely conducted by a team comprised of approximately 15 Federal employees and that the support required of the contractor would be limited. NNSA actively pursued acquiring federal staff to support the project; however, was unable to do so due to overall agency funding/hiring restraints and insufficient numbers of qualified personnel available. The lack of availability of qualified federal staff necessitated the use of increased contractor support to enable successful completion of the project.

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IX. STEPS TO FOSTER COMPETITION

No structural or procedural barriers to competition have been identified. NNSA will continue to review actions on a case by case basis with the intent of maximizing competition in accordance with Fair Opportunity and the Competition in Contracting Act.