FA286026P0013 Other than full and open justification.pdf

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Fuel Release Cleanup
Solicitation number
FA286026P0013
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This is a Department of the Air Force Justification for Other Than Full and Open Competition (J&A) document dated 21 April 2026, approved by Contracting Officer Clifford Roberts. The acquisition is valued under $10 million and authorizes a sole-source award to Clean Harbors Environmental Services Inc on a Time and Materials basis.

The contracting activity is the 316 Contracting Squadron at Joint Base Andrews, Maryland, acting on behalf of AFDW. The requirement involves containment, capture, and disposal of jet fuel and jet fuel byproduct from Piscataway Creek following an unforeseeable fuel spill at the installation. The statutory authority for the sole-source exception is 10 U.S.C. 3204(a)(2), which permits procurement on an unusual and compelling urgency basis. The justification emphasizes that the exact source, volume, and extent of contamination are currently unknown, necessitating immediate remediation and containment services to mitigate severe environmental damage, prevent hazards to life and property, avoid regulatory penalties, and control escalating cleanup costs. Clean Harbors was identified through accelerated market research as the only vendor with the immediate capacity, specialized hazardous materials equipment, certified personnel with existing base access, and proven ability to respond within hours. The action is strictly limited to this emergency response, with the understanding that future fuel remediation efforts will allow adequate time for competitive procurement and detailed Statements of Work.

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Department of the Air Force: Justification for Other Than Full and Open Competition

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Dollar Value of this Acquisition: < $10M > $10M and < $100M > $100M and < $500M > $500M

CERTIFICATIONS: CO certification serves as J&A approval < $10M, See J&A Template Guidance at https://usaf.dps.mil/sites/ AFCC/AQCP/KnowledgeCenter/SitePages/DAF-Contracting-Compass/Part-6---Competition-Requirements.aspx#exceptions-to-full-and-open-competition-mandatory J&A Template Guidance tab

Date

21 April 2026

Contracting Officer (RFO 6.104-1(12)) Clifford Roberts

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

Signature

Date Technical and Requirements Personnel (RFO 6.104(b)) [Name ]

I certify that the supporting data herein, which is my responsibility, is accurate and complete.

Signature

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APPROVALS ( RFO 6.104-2(a) Table 6-1 & R-DFARS 206.104-72 Table 206.1)

See J&A Template Guidance (https://usaf.dps.mil/sites/AFCC/AQCP/KnowledgeCenter/SitePages/DAF-Contracting-Compass/ Part-6---Competition-Requirements.aspx#exceptions-to-full-and-open-competition-mandatory) - Justification Approvals tab

NOTE 1: A signature block will appear here (replacing these notes) based on the "Dollar Value of this Acquisition" selected above. Since most digital signatures that include date/time-stamps are redacted before they are made publicly available, always insert the date in the “Date” cell when affixing a digital signature to this document.

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I. Agency and Contracting Activity (RFO 6.104-1(a)(1)):

Agency: AFDW Joint Base Andrew,MD Contracting Activity: 316 Contracting Squadron, Joint Base Andrews, MD

II. Nature and/or description of the action being approved (RFO 6.104-1(a)(2)):

This document approves the award of a Time and Materials Purchase Orders on a Sole Source basis to Clean Harbors Environmental Services Inc to contain, capture, and dispose of jet fuel and jet fuel byproduct from Piscataway Creek. This justification is made on an unusual and compelling basis.

III. Description of supplies/services required to meet agency needs (RFO 6.104-1(a)(3)):

Provide a clear and concise description of the supplies or services to be acquired (including the necessary IP required to meet the program and mission needs), the estimated value (including all options), appropriation and funding amounts planned, anticipated contract type, major items and associated quantities.

IV. Statutory Authority Permitting Other Than Full and Open Competition (RFO 6.104-1(a)(4)):

10 U.S.C. 3204(a)(2), Unusual and compelling urgency.

V. Rationale for Use of Authority (RFO 6.104-1(a)(5)):

A fuel spill has occurred at Joint Base Andrews. Currently, the exact source of the leak, the total volume of fuel spilled, and the physical extent of the contamination are unknown. Immediate remediation and containment services are required to mitigate severe environmental damage. Any delay in awarding a contract to allow for full and open competition would result in unacceptable hazards to life, property, and the environment, as well as exponentially increasing cleanup costs and mission degradation.

VI. Integrated Market Analysis and Efforts to Solicit Competition (RFO 6.104-1(a)(6), (8), and (10)):

Due to the urgent and compelling nature of the fuel spill, standard market research was not feasible. The market research focused on identifying vendors with the immediate capacity, specialized equipment, and certified personnel required to respond to hazardous material spills on a military installation within hours. Clean Harbors was identified through this accelerated research as a capable vendor. They possess the required capabilities, capacities, equipment on base, and personnel with base access. Their rapid ability to respond to the fuel spill was pivotal.

VII. Determination of Fair and Reasonable Cost (RFO 6.104-1(a)(7)):

The Contracting Officer is responsible for evaluating, determining, and documenting the anticipated contract cost/price is fair and reasonable in accordance with RFO Subpart 15.4, Contract Pricing.

VIII. Any Other Facts Supporting the Justification (RFO 6.104-1(a)(9)):

Failure to immediately secure the comprehensive services of Clean Harbors will likely result in widespread ecological impact, and significant regulatory fines or penalties against the installation. The urgency of this procurement is heavily driven by environmental efforts, increasing costs, and public interest.

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IX. Actions to Overcome Barriers to Competition (RFO 6.104-1(a)(11):

The current sole-source, Time and Materials (T&M) action is strictly limited to mitigating this immediate, unforeseeable emergency where the source, volume, and required effort are currently unknown and pose an imminent threat to the installation. Future fuel issues will be known and quantified in advance, the requiring activity will have the ability to develop clear, highly defined Statements of Work (SOW) well ahead of any required remediation or repair.

March 2026 Page of Dollar Value of this Acquisition:

CERTIFICATIONS: CO certification serves as J&A approval < $10M, See J&A Template Guidance at https://usaf.dps.mil/sites/AFCC/AQCP/KnowledgeCenter/SitePages/DAF-Contracting-Compass/Part-6---Competition-Requirements.aspx#exceptions-to-full-and-open-competition-mandatory J&A Template Guidance tab

COORDINATION

** The text in the signature blocks below is editable, including the title.

** To remove a row, click the "X" next to the signature block. CAUTION: Once removed, it can only be restored by downloading the BLANK FORM again.

APPROVALS ( RFO 6.104-2(a) Table 6-1 & R-DFARS 206.104-72 Table 206.1) See J&A Template Guidance (https://usaf.dps.mil/sites/AFCC/AQCP/KnowledgeCenter/SitePages/DAF-Contracting-Compass/Part-6---Competition-Requirements.aspx#exceptions-to-full-and-open-competition-mandatory) - Justification Approvals tab NOTE 1: A signature block will appear here (replacing these notes) based on the "Dollar Value of this Acquisition" selected above. Since most digital signatures that include date/time-stamps are redacted before they are made publicly available, always insert the date in the “Date” cell when affixing a digital signature to this document.

I. Agency and Contracting Activity (RFO 6.104-1(a)(1)):

II. Nature and/or description of the action being approved (RFO 6.104-1(a)(2)):

III. Description of supplies/services required to meet agency needs (RFO 6.104-1(a)(3)):

IV. Statutory Authority Permitting Other Than Full and Open Competition (RFO 6.104-1(a)(4)):

V. Rationale for Use of Authority (RFO 6.104-1(a)(5)):

VI. Integrated Market Analysis and Efforts to Solicit Competition (RFO 6.104-1(a)(6), (8), and (10)):

VII. Determination of Fair and Reasonable Cost (RFO 6.104-1(a)(7)):

VIII. Any Other Facts Supporting the Justification (RFO 6.104-1(a)(9)):

IX. Actions to Overcome Barriers to Competition (RFO 6.104-1(a)(11):

9.0.0.2.20120627.2.874785

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Date: 21 Apr 2026
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Authority: 10 U.S.C. 3204(a)(2), Unusual and compelling urgency.
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