Follow-on_JOFOC Eastern NASA Manufacturing Technology Transfer Center - Final.pdf

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NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

GODDARD SPACE FLIGHT CENTER (GSFC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For Eastern NASA Manufacturing Technology Transfer Center (E-NMTTC) Workmanship Training Contract

1. Federal Acquisition Regulation (FAR) 6.303-2(b)(1) – Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for other than full and open competition.”

This document is a justification for other than full and open competition prepared by National Aeronautics and Space Administration (NASA) Goddard Space Flight Center

(GSFC).

The procuring agency is NASA, and the contracting activity is GSFC (Greenbelt, MD).

2. FAR 6.303-2(b)(2) – The nature and/or description of the action being approved:

This justification provides the rationale for contracting by other than full and open competition to award a sole source contract as a follow-on to 80GSFC18C0023 with KBR Wyle Services, LLC (KBR) for training courses to be delivered by NASA Level A certified instructors and Certified Institute for Printed Circuits (IPC) Trainers (CIT) and compliant with NASA’s internal policies for operating NASA’s Workmanship Training Center. The current $1.3M contract 80GSFC18C0023 with KBR ends November 02, 2022.

3. FAR 6.303-2(b)(3) – A description of the supplies or services required, to meet the

Agency’s needs (including the estimated value):

The services and operations sought include providing all qualified personnel, facilities, and equipment for the delivery of workmanship training courses to NASA GSFC, other NASA field Centers, industry, other US Government Agencies including the Department of Defense (DoD), academia, and non-US entities such as the Canadian Space Agency. The curriculum for the courses, including the definition of all class materials, is predefined and pre-existing.

These courses are a mixture of classroom instruction and hands-on practicum that require specialized facilities. These specialized facilities enable the hands-on practicum portion of training to achieve an effective and controlled training environment while ensuring the safety of students and government furnished equipment. This training supports the Safety and Mission Assurance mission by: 1) offering training to reduce electronics manufacturing and handling performance risks; 2) reinforcing high reliability requirements for the space industry; and 3) working towards a 100% mission success rate.

Training topics include, but are not limited to, operators performing soldering, conformal

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The effective ordering period of this contract will be for a period of five (5) years from the contract effective date. The estimated dollar value for this action is $1.9M.

4. FAR 6.303-2(b)(4) – An identification of the statutory authority permitting other than full and open competition:

The statutory authority permitting other than full and open competition is 10 U.S.C.

2304(c)(1) as implemented by FAR 6.302-1 “Only one responsible source and no other supplies or services will satisfy agency requirements.”

5. FAR 6.303-2(b)(5) – A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited:

The rationale supporting the use of 10 U.S.C. 2304(c)(1) is “Only one responsible source and no other supplies or services will satisfy agency requirements” as described below.

NASA GSFC requires near-site workmanship training to be conducted by NASA Level A certified instructors. Workmanship training and recertification, as defined in Policy NASA- STD-8739.6A, is required every two years. To minimize disruption to mission critical services with a number of trainees/participants who are design and assembly critical providers, just-in-time workmanship training is imperative, especially those trainees supporting flight Projects with tight schedules. Having the training near-site cuts down on the trainees’ time away from work. This time-savings is notable, as there are a large number of participants requiring workmanship training (e.g. in the case of ESD, about 981 employees are currently required to keep their training current).

Currently, KBR is the only contractor that has NASA Level A certified instructors in a near- site location. KBR is able to provide a classroom facility that accommodates both lecture and practical instruction that is functional and safe for the students. KBR’s facility provides for adequate ventilation when soldering is being performed and control of optical fiber scrap to prevent injury. The facility also meets the National Environmental Policy Act (NEPA), mini-NEPA (regarding local environmental laws) and Occupational Safety and Health Administration (OSHA) requirements.

6. FAR 6.303-2(b)(6) – A description of the efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies:

A notice to the Government Point of Entry (GPE) website (SAM.gov) was published on April 21, 2022 and closed May 06, 2022 at 5:00pm ET in accordance with FAR Subpart

5.2. This posting informed potential sources of NASA’s intent to award this sole-source contract to KBR. The results of this synopsis are summarized in Section 10 below.

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7. FAR 6.303-2(b)(7) – A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable:

The Contracting Officer’s (CO) signature on this document indicates that the CO has determined that the anticipated cost to the government will be fair and reasonable. The Contractor shall be required to submit a proposal to be evaluated and negotiated by the Government. Prior to execution of the contractual instrument, a proposal analysis will be performed. The proposal analysis will ensure that the final agreed-to price for the contract action is fair and reasonable.

The proposed costs will be evaluated by the Contracting Officer’s Representative (COR) and the CO to determine that the direct labor rates, direct labor hours, skill mix, other direct costs, indirect costs, and fee(s) are fair and reasonable. This may also include support from external organizations such as the Defense Contract Audit Agency, as needed.

8. FAR 6.303-2(b)(8) – Description of the market research conducted, and the results, or a statement of the reasons a market research was not conducted:

In March 2022, the COR performed market research by reviewing the System for Award Management (SAM) to identify potential sources appropriate for the contract’s requirements. The contract requires services and operations that provide workmanship training courses to NASA GSFC employees and affiliated contractors/personnel. These courses require a mixture of in-person classroom instruction and hands-on practicums with specialized facilities, and these facilities need to be local to NASA GSFC. Based on the review, only one source (KBR) was identified as capable of fulfilling all of the E-NMTTC Workmanship Training contract’s requirements.

Other potential sources were limited in capability and could potentially serve on temporary rotational assignments as Quality Assurance Specialists or Engineers as a means to increase knowledge of current workmanship processes and practices, but these sources were determined to be unable to perform the entirety of the contract’s unique and highly specialized requirements. For example, NASA STD 8739.6 requires that instructors be certified as NASA Level A Trainers and these sources are unable to adhere to this standard.

9. FAR 6.303-2(b)(9) – Any other facts supporting the use of other than full and open competition:

None.

10. FAR 6.303-2(b)(10) – A listing of the sources, if any, that expressed an interest in writing in the acquisition:

A notice of NASA’s intent to award this sole-source action was synopsized on the GPE website (SAM.gov) per FAR Subpart 5.2 (See Section 6 above). The action was posted on

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April 21, 2022 and closed May 06, 2022 at 5:00pm ET. The synopsis notified all interested sources that a requirement would be issued on a sole-source basis and provided potential offerors an opportunity to respond within 15 days of publication. Only the incumbent (KBR) submitted a response via email on May 06, 2022 at 10:30am ET.

11. FAR 6.303-2(b)(11) – A statement of actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required:

The E-NMTTC Workmanship Training Statement of Work has been reviewed to verify that it reflects GSFC’s minimum requirements and is not unduly restrictive. The Agency will continue to examine the market in the future for alternative solutions or new sources before executing any subsequent acquisitions for the same requirements.

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Eastern NASA Manufacturing Technology Transfer Center (E-NMTTC) Workmanship Training Contract

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIGNATURE PAGE

I certify that the facts presented in this justification are accurate and complete.

Eric M. Borrero Technical Representative

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

Sherika Wilson Contracting Officer

CONCURRENCE:

Mary V. Stevens Procurement Officer (Acting)

APPROVED:

Raymond J. Rubilotta Competition Advocate Goddard Space Flight Center

Eric Borrero Borrero

Date: 2022.04.07 16:40:11 -04'00'

SHERIKA

MARY

STEVENS

Digitally signed by

MARY STEVENS

Date: 2022.05.10

18:25:47 -04'00'