DON_SAP_Single_Source_N3943026P5007.pdf

AUG 2018

Subj: USE OF OTHER THAN FULL AND OPEN COMPETITION FOR AN

ACQUISITION UNDER THE SIMPLIFIED ACQUISITION THRESHOLD

I. BACKGROUND:

1. For purchases not exceeding the simplified acquisition threshold, Contracting Officers may restrict competition if the Contracting Officer determines that the circumstances of the contract action deem only one source reasonably available (e.g. urgency, exclusive licensing agreements, brand-name or industrial mobilization). Ref. Rev. FAR Overhaul (RFO) 12.102(a)

2. This memorandum documents the absence of competition for this acquisition, as only one source will be solicited for this requirement and the requirement is not expected to exceed the simplified acquisition threshold ($350k).

II. DESCRIPTION OF ITEM OR SERVICE:

This contract action is to award a sole-source contract to Eurofins Lancaster for specialized chemical laboratory analytical services.

The contractor shall provide all sampling containers, solvents, wipes, chains of custody, other materials, shipping labels, and analytical chemistry services to perform chemical analysis of wipe samples collected from the Red Hill Bulk Fuel Storage Facility. The work requires a unique and complex combination of analytical methods, most notably custom sample preparation developed by Eurofins Lancaster Laboratories in conjunction with NAVFAC EXWC to overcome foaming issues during the development of the modified ASTM D6661 wipe sampling methodology. Eurofins Lancaster Laboratories has extensive experience in developing and troubleshooting the adaptation of this sampling technique for the characterization of residue on tank walls using wipe samples. Eurofins Lancaster Laboratories is the only analytical laboratory who developed this modified application of ASTM Method D6661. Another specialized analysis is Alkylated Polycyclic Aromatic Hydrocarbons (PAHs) using EPA Method 8270E in Selective Ion Monitoring (SIM) mode, a non-standard and highly specialized technique.

Prior contract history directly with Eurofins does not exist. However, historical work was done with Eurofins through EXWC’s Environmental Science and Engineering Contract (ESEC) contractor, Jacobs-Geosyntec Joint-Venture as a component of a broad RDT&E program that EXWC was tasked with by the Navy to identify the most favorable method for Red Hill Bulk Fuel Storage Facility tank cleanliness verification. This effort included high-volume air sampling, extensive ultraviolet radiation detection experiments to determine the efficacy of confirming tank cleanliness using UV light, analytical wipe sampling using ASTM Method D6661, as well as a number of other efforts. Ultimately, US EPA, HI DOH and the Navy together through a series of negotiation meetings selected wipe sampling due to its ability to characterize residual residue remaining on tank walls following cleaning. Now that the RDT&E phase is over, it is no longer appropriate to use ESEC Jacobs-Geosyntec JV. The EXWC KO and ESEC CORs identified the most appropriate path forward is to use the simplified acquisition procedure and sole source justification to contract directly with Eurofins to execute the focused RHBFSF tank cleanliness verification scope of work.

Eurofins Lancaster is the only source capable of meeting the government's requirements without causing unacceptable schedule delays and significant duplication of cost. This is based on the following:

Intimate Project-Specific Knowledge: Eurofins Lancaster was the analytical laboratory subcontracted to support the development of the original sampling methodology in EXWC’s in-house study. Eurofins Lancaster Laboratories was subsequently involved in the technical consultations with NAVFAC EXWC and the Navy Closure Task Force - Red Hill (NCTF-RH) that led to the revised, final methodology of February 2026. This gives Eurofins Lancaster an unparalleled and unique understanding of the project's technical nuances, data quality objectives, and specific reporting requirements, including the critical data use limitations for Alkylated PAH results.

Continuity and Data Comparability: As the incumbent laboratory involved in the methodology development, using Eurofins Lancaster ensures analytical continuity and consistency. A new laboratory would lack the historical context and could introduce inter-laboratory variability, potentially complicating data interpretation and comparability with earlier datasets, which would be detrimental to this high-visibility project.

Unique, In-Place Capability: The requirement to analyze for Alkylated PAHs using EPA Method 8270 in SIM mode is a highly specialized service not offered by most commercial environmental laboratories. Eurofins Lancaster has the specific instrumentation, certified methods, and trained personnel already in place to perform this analysis. A competitive procurement would require other labs to develop, certify, and validate this method, a process estimated to take several months and introduce significant technical risk and unacceptable delays to the high-priority Red Hill closure schedule. Note: this is the key item for justification of urgent action of this documentation – samples need to be secured concurrently with scheduled work by construction contractor to be on-site for Remediation work at the Red Hill site in May 2026, and re-mobilizing any contractor to reopen the site is anticipated to severely impact the US Navy, and represent an unacceptable cost risk.

Based on the unique technical requirements and Eurofins Lancaster’s exclusive project-specific knowledge and in-place capabilities, it is determined that only one source is reasonably available to perform this work within the required timeframe and to the required level of quality.

Awarding a sole-source contract to Eurofins Lancaster is in the best interest of the Government.

III. THE DETERMINATION FOR USE OF OTHER THAN FULL AND OPEN

COMPETITION IS BASED ON THE FOLLOWING:

A. ONLY ONE RESPONSIBLE SOURCE (select all that apply):

1. RESTRICTIVE RIGHTS. The source has established proprietary rights, limited rights in data, patent rights, copyrights or secret processes in the item or service required.

2. EXCLUSIVE LICENSING AGREEMENTS. The item or service is only available from the Original Equipment Manufacturer (OEM), or there is only one authorized distributor or technical representative for the OEM.

3. OTHER REASONS.

B. BRAND NAME. Item required must be a brand name product, or feature of a product, particular to one manufacturer.

C. _X UNUSUAL AND COMPELLING URGENCY. The supplies or services are of such unusual and compelling urgency that the Government would be seriously injured unless the agency is permitted to limit the number of sources from which it solicits bids or proposals. Urgent requirements are supplies or services that will result in a work stoppage, or are mission critical and the routine processing time would result in injury to the Government.

The determination that the procurement for the above item/service is an urgent and compelling requirement is based on the following:

1. Date on which the requirement was first identified: 27FEB 2026

2. Required delivery date/period of performance: 30April 2026 – 30April 2027

3. Explanation of why delivery/commencement of services by the date mentioned above is required: Navy Closure Task Force-Red Hill is legally obligated to meet the closure timeline outlined in the Administrative Order on Consent between USEPA and the Department of the Navy.

4. If appropriate, include any additional pertinent information.

IV. CERTIFICATIONS/APPROVALS:

Technical / Requirements Certification: I certify that the facts and representation under my cognizance which are included in this justification are complete and accurate to the best of my knowledge and belief.

16 APR 2026

Benjamin L. Rhiner / 805-982-1694 Date

Contracting Officer Approval

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

16 APR 2026

Ryan J. Kenniff / 619-705-4260 Date