JA-24-Edg-030 Hazardous Waste-Redacted.pdf

CUI

Control Number: JA-24-Edg-030

Justification Review Document for Other than Full and Open Competition - FAR Part 6

Program/Equipment: Disposal of hazardous waste resulted from the treatment of various chemical agents and/or biological agents.

Authority: 10 United States Code (U.S.C.) 3204(b)(B) as implemented by Federal Acquisition Regulations (FAR) Part 6.302-1(a)(2), only one responsible source and no other supplies or services will satisfy agency requirements.

Amount: $24,913,872.86

Prepared by: John Barczak Biologist Email: john.m.barczak.civ@army.mil

DSN: 867-2778

Date: 11 Dec. 2023

Contracting Officer: Nicholas Granata Jr.

Contracting Officer Email: nicholas.granata.civ@army.mil

DSN: 584-2739

Date: 11 Dec. 2023

Technical Rep: Amy Dean Project Engineer Email: amy.l.dean14.civ@army.mil

DSN: 584-7073

Date: 11 Dec. 2023

Requirements Rep: Brian O’Donnell Chief, Project Development Team Email: brian.j.odonnell26.civ@army.mil

DSN: 584-4180

Date: 11 Dec. 2023

Controlled by: United States Army Controlled by: ACC-APG CUI Category: General Procurement and Acquisition Distribution/Limited Dissemination Control: FEDCON POC: Nicholas Granta, Jr., 520-671-3742 mailto:john.m.barczak.civ@army.mil mailto:nicholas.granata.civ@army.mil mailto:amy.l.dean14.civ@army.mil mailto:brian.j.odonnell26.civ@army.mil

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Program Manager:

Timothy Blades, Chief, CB Operations

DSN: 584-4675

Signature: Date:

Legal Counsel:

Typed Name:

DSN:

RUDOLPH.RUBEN.D Digitally signed by

ARIO.JR.155054326 RUDOLPH.RUBEN.DARIO.JR.155054

1 Date: 2024.02.09 12:50:22 -05'00'

Signature: Date:

Command Advocate for Competition:

Jason E. VanLuven:

Phone: 520-671-3284

Signature: Date:

Justification and Approval for Other than Full and Open Competition – FAR Part 6

1. Contracting Activity: U.S. Army Contracting Command – Aberdeen Proving Ground (ACC- APG), Edgewood Contracting Division, CCAP-DDE, Aberdeen Proving Ground, MD 21010- 5401.

2. Description of Action: The Combat Capabilities Development Command's (DEVCOM) Chemical Biological Center (CBC) requests a new Firm-fixed price (FFP) indefinite delivery/ indefinite quantity (IDIQ) contract with Veolia ES Technical Solutions, LLC., (VES), 53 State Street, Suite 14, Boston MA. The Government anticipates awarding the first task order in February 2024. Fiscal year 2024 Operations and Maintenance funds in the amount of $2,500.00 will be immediately obligated to meet the stated minimum quantity. The ceiling value for this contract is $24,913,872.86. This action continues services performed under W911SR-18-D-0010.

3. Description of Supplies/Services: This contract is for the management and disposal of waste contaminated with chemical or biological agents, or other high hazard contaminants. The management aspect of this effort includes the provision of subject matter expertise on decontamination methods, and the associated packaging, transportation, and disposal methodology. Further, because of the highly specialized nature of these wastes, the contractor may need to provide environmental and treaty services. For example, under the previous contract, VES was obligated to petition the Environmental Protection Agency to bring back waste that was generated in Panama. Similarly, for waste streams that fall under the purview of the Chemical Weapons Convention, they may be obligated to comply with providing specialized treaty requirements such as cameras, security, and other miscellaneous mandates.

A unique component to fulfilling this Government requirement is for the transport, management, and disposal of agent contaminated waste greater (>) than 1.0 Vapor Screening Level (VSL). A VSL is a chemical agent’s Short Term Exposure Level that is independent of time. The DEVCOM CBC specification requires the containers NOT be opened due to the health risks and hazards from exposure. Disposing of the containers without opening them is imperative to this requirement, and requires a specific capability, as the entire sealed drum needs to be deposited without opening and/or breaking the seal.

Ordering Period: 15 February 2024 to 14 February 2029:

Base Year Estimate: $4,814,193.38 Option Year 1 Estimate: $4,868,355.16 Option Year 2 Estimate: $4,972,079.38 Option Year 3 Estimate: $5,078,725.77 Option Year 4 Estimate: $5,180,519.17 Total Value: $24,913,872.86

Task orders are awarded as world events unfold both in the United States and abroad, often as an urgent requirement. As a result, a fixed annual funding level is not possible to forecast. The Independent Government Estimate (IGE) assumes a level requirement over the five-year ordering period. The ceiling amount is based on historical pricing of services, and increased requirements are based on forecasted estimates, to include other organizations being able to leverage this award.

4. Authority Cited: 10 U.S.C. 3204(a)(1) as implemented by FAR 6.302-1(a)(2), only one responsible source and no other supplies or services will satisfy agency requirements.

5. Reason for Authority Cited: As explained below, these highly unique services are available from only one source. Extensive market research validates an award to any other source would result in unacceptable delays in fulfilling the agency’s requirements because no other source is licensed to provide these services.

The Chemical Biological Application and Risk Reduction (CBARR) organization is a business unit within DEVCOM CBC that is specifically tasked with the handling, treatment, and disposal of research waste, highly concentrated traditional waste, secondary waste resulting from chemical agent decontamination, and other high-hazard waste on a global basis. This requirement was previously handled by the U.S. Army Chemical Materials Activity (CMA), then was formally transferred to CBARR in May 2015. The handling of these waste products is extremely hazardous and highly specialized. As a result, a contractor handling these products requires special licenses and permits, to include the Resource Conservation and Recovery Act (RCRA) and Clean Air Act (CAA) permits to avoid the serious health risks associated with improper handling and disposal. In addition, the Government conducts its own capability review to ensure the contractor can meet the additional requirements not otherwise covered by state and federally issued permits. The contractor must also have the capability of moving certain highly hazardous waste on an immediate basis.

CBARR supports: (1) the entire DoD (including the Pentagon); (2) other federal agencies such as the Department of Homeland Security (DHS); (3) the Environmental Protection Agency (EPA);

and (4) various commercial entities. CBARR’s mission has intense oversight from State regulators and international agencies. A contractor handling these products is subject to inspections accordingly and must comply with the guidelines and procedures of the Chemical Weapons Convention (CWC) 1997.

There are numerous companies that have the RCRA and CAA permits across the country.

However, in addition to these permits, the specific waste covered by this contract is regulated by the Chemical Weapons Convention 1997.

The Chemical Weapons Convention (CWC) 1997, allows four methods of disposal of hazardous waste as follows:

1. Incineration

2. Bio treatment

3. Neutralization of agent

4. Super critical water oxidation

The CWC requirement for DEVCOM CBC's hazardous waste is incineration.

There are several States with permitted hazardous waste incinerators. . The DEVCOM CBC specification requires an incinerator be able to receive and process the containers without them being opened and sampled due to the health risks and hazards from exposure. For the 20 years the Army has been shipping agent contaminated waste for commercial incineration, only one company has sought and received approval from their State regulator to process the waste WITHOUT opening the drums. This approval was requested of, and approved by, the Texas Commission on Environmental Quality. Disposing of the containers without opening them requires a specific capability as the entire sealed drum needs to be deposited without opening and/or breaking the seal.

The key component to fulfilling the Government’s unique requirement is for the transport, management, and disposal of agent contaminated waste greater than 1.0 VSL. Agent contaminated waste greater than 1.0 VSL have chemical agents at a level that could cause significant harm to human health, and even death if the containers/waste are not handled/treated appropriately and compliantly by the vendor.

VES is the only source to seek and receive approval to receive and treat this waste in accordance with the strict requirements defined by the Government. Additionally, VES has the necessary expertise and experience required to complete this requirement as evidenced by the following:

• Two U.S. Army Chemical Weapons incinerators were operated in the Tooele, Utah and Umatilla, Oregon facilities. While these facilities were owned by the Army, they were operated by a contractor. While destroying the United States stockpile of chemical weapons, high level agent contaminated waste was generated, and the Army facility was not best suited to destroy this contaminated waste. Therefore, contractors for both facilities awarded contracts to VES to dispose of this high-level agent contaminated waste stream.

• The Newport, Indiana chemical agent facility (NECDF) generated hydrolysate from the neutralization of chemical agent. The original contract for disposal of this waste was through Parsons (the prime contractor for the NECDF facility) and was with Permafix in Ohio. Ultimately, Permafix could not obtain permits and approvals for acceptance and disposal of the Newport hydrolysate. That contract between Parsons and Permafix was then terminated. The disposal of the hydrolysate was descoped from the Parsons contract and the U.S. Army awarded a contract to VES for the disposal of the hydrolysate.

• VES owns and operates the Port Arthur Facility in Texas. This facility is the only facility in the U.S. meeting the environmental and operational requirements necessary for this requirement. The Port Arthur facility has undergone a detailed capability assessment to ensure it can successfully treat this highly hazardous waste requirement. Personnel at this facility have been provided additional training and VES has instituted additional procedures to ensure worker safety. Additionally, VES allows DEVCOM CBC personnel to do on-site monitoring of the delivery trucks to ensure there are no leaks from the waste containers prior to opening the truck for waste processing. This facility further has a direct feed of the drums to the incinerator, without the need for opening the individual drums. The facility also has a snorkel system in place to safely evacuate the air in the trailer to the incinerator should it become contaminated due to a leaking drum. No other facility located in the U.S. has the needed technology to appropriately process and dispose of highly contaminated chemical and biological waste.

• VES has the ability to safely transport, manage and dispose of agent contaminated waste greater than 1.0 VSL. Market research demonstrated no other vendor was able to support this critical requirement.

6. Efforts to Obtain Competition: The Contracting Officer shall publish the notices required by FAR 5.201 and 6.302-1(d) and any bids or proposals received shall be considered. There were two RFIs posted for this upcoming action. The Contracting Officer took significant steps to ensure all responses to the Request for Information (RFI)/Sources Sought (hereinafter jointly referred to as “RFI”) were fully vetted. The first RFI in preparation for W911SR-23-R-HAZW, was posted to Sam.Gov on 12 October 2022 under NAICS code 562211, Hazardous Waste Treatment and Disposal. Responses to the notice were due by 15 November 2022. Four responses were received, additional information of each response is found below in Section 8.

Market Research. One contractor from the first RFI (October 2022), showed interested in this requirement but submitted incomplete information in their response. The original goal of the acquisition planning milestones was to have the market research phase from approximately October 2022 to May 2023. However, the Contracting Officer took more than reasonable steps to obtain competition by extending the original market research milestones phase to allow for the interested vendor to submit the incomplete information from their original response. The Contracting Officer, sending multiple emails, making phone calls, and leaving voicemail messages to the interested vendor, with many of times, emails and phone calls not being returned, gave the interested vendor a deadline of 5 September 2023. From this final submission, extensive market research, and the support of the DEVCOM CBC Technical Team, the Contracting officer reasonably determined no other contractor, besides VES, possess the mandatory facilities, license and permits, and has shown the ability to meet the Government’s unique requirement.

The second RFI was posted to Sam.Gov on 26 January 2024 under NAICS code 562211, Hazardous Waste Treatment and Disposal. Responses to the notice were due by 5 February 2024. Only one response was received, which was VES. Additional information of responses is located below in Section 8

a. Effective competition. Effective competition is not anticipated for this requirement based on the above and extensive market research efforts, as detailed below in Section 8 “Market Research.”

b. Subcontracting competition. FAR 52.244-5, Competition in Subcontracting, will be included in the resultant contract which states that the Contractor shall select subcontractors (including suppliers) on a competitive basis to the maximum practical extent consistent with the objectives and requirements of the contract. A subcontracting plan is required for this effort.

7. Actions to Increase Competition: The regulations associated with the disposal of chemical, biological, and other high hazard waste, are burdensome and the marketplace is relatively small, making it difficult to encourage increased competition. For safety reasons, the regulations cannot be loosened, so the marketplace for these services is expected to remain the same for the foreseeable future. Also, the EPA website does have a search tool for identifying hazardous waste sites, including waste generators, recyclers, etc. The site does not list sites that store or dispose of high hazard waste, like the types included in this contract (see https://rcrapublic.epa.gov/rcrainfoweb/action/modules/hd/handlerindex).

However, the Government will continue to exhaust as many market research techniques as is practical for this type of requirement, such as, but not limited to; issuing formal requests for information and sources sought, contacting knowledgeable people in the industry, contacting other Government Contracting and Project Offices, conducting site visits if any potential new hazardous waste disposal facilities are identified, and continuous monitoring of the industry.

8. Market Research: DEVCOM CBC conducts market research on a regular basis by posting Sources Sought notices and RFI notices through Sam.Gov. DEVCOM CBC conducts these postings to continually assess the current market and ensure the mission is always met by utilizing the most qualified vendor. The following postings were completed prior to this date:

a. A RFI in preparation for W911SR-23-R-HAZW, was posted to Sam.Gov on 12 October 2022 under NAICS code 562211, Hazardous Waste Treatment and Disposal. Responses to the notice were due by 15 November 2022- (over 30 days).

In each posting, interested vendors were asked to provide the following:

• The firm's approach for meeting all portions of the specific scope elements.

• The firm’s experience in implementation of environmental safety and health plans related to the transportation and disposal of chemical and biological agent contaminated waste.

• The firm's recent and relevant experience and performance record. The RFI specifically asks for demonstration of experience with:

o Current permit conditions that would allow for the treatment of agent contaminated waste;

o Chemical agent contaminated waste transportation, management and disposal (> and < 1 Vapor Screen Level (VSL));

o Biological agent contaminated waste transportation, management and disposal;

o Compliance with Chemical Weapons Convention (CWC) and Organization for the Prohibition of Chemical Weapons (OPCW) requirements;

o Working with stakeholders and regulatory agencies at the state and federal level;

o Compliance history related to the transportation, management and disposal of chemical and/or biological contaminated waste;

o Working within the Incident Command Structure (ICS) during a transportation and disposal operation; and o Experience with transportation and disposal of other military unique items.

b. DEVCOM CBC analyzed four responses to the RFI.

1. Bear Environmental. This company is an environmental company. They submitted a one-page submittal which provides no information regarding waste disposal, much less disposal of waste contaminated with chemical or biological agent. This company was considered non-responsive to the RFI and is not considered a viable candidate for the scope of work as defined in the RFI.

2. Paragon Professional Services. While Paragon’s submittal provided information on their management of hazardous waste, they were not able to provide experience with the management of chemical or biological agent contaminated waste as requested by the RFI.

From the submittal it also looks like Paragon would be relying heavily on subcontractors and sister companies. Some of these companies have general hazardous waste experience, but none have specific experience with handling, managing, and disposal of chemical or biological agent contaminated waste. In the submittal Paragon stated, “Paragon will review all descriptions of waste, waste profiles and quantities and recommend disposal and transportation options to the DEVCOM”. Under the RFI the Government was not looking for a contractor who could provide options, the Government requested information on companies that can handle, manage, transport, and dispose of the subject waste. This company was considered non-responsive to the RFI and not considered a viable candidate for the scope of work as defined in the RFI.

3. Clean Harbors. The submittal from Clean Harbors provided information on past projects and disposal facilities that could accept the Governments chemical and biological agent related wastes. However, their Capability Statement, seems to be misleading, as Clean Harbors has never transported, managed, or disposed of > 1 VSL chemical agent contaminated waste. The evaluators of these RFI responses have first-hand experience with evaluating Clean Harbors for acceptance of chemical agent related waste from Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP), to include site and assistance visits. The evaluators knew Clean Harbors contract for BGCAPP was terminated based on their inability to both develop plans and procedures for the transport, and handle and dispose of > 1 VSL chemical agent contaminated wastes at Clean Harbor facilities. The Government was looking for a contractor who can handle, manage, transport, and dispose of all the categories of waste outlined in the RFI. The Contracting Officer followed up numerous times with Clean Harbor’s because they did not address the very important aspect of fulfilling the upcoming contract’s requirement of transporting, managing, or disposing of > 1 VSL chemical agent contaminated waste. The Contracting Officer followed up with Clean Harbors in early May 2023 and made numerous requests to allow them to make their market research submission complete. Clean Harbors finally responded in late June 2023 and still provided no evidence of experience treating > 1 VSL waste. In August 2023, ACC told Clean Harbors their response was not sufficient, and they were given one last opportunity to demonstrate their experience with > 1 VSL waste. In September 2023 Clean Harbors confirmed they have no experience with > 1 VSL waste. Clean Harbors was considered non-responsive to the RFI and not considered a viable candidate for the scope of work as defined in the RFI.

4. VES submitted a response which included numerous examples of their direct experience with the management and disposal of chemical and biological agent contaminated hazardous waste. VES also provided a detailed discussion of their destruction technology at the Port Arthur, Texas facility (described in Section 5 above). VES demonstrated they have direct responsibility for the treatment and disposal of with > 1 VSL hazardous waste.

c. A second RFI was posted to Sam.Gov on 26 January 2024 under NAICS code 562211, Hazardous Waste Treatment and Disposal. Responses to the notice were due by 5 February.

Interested vendors were asked to address:

• The firm’s approach for meeting all portions of the specific scope elements.

• The firm’s recent and relevant experience and performance record.

• The firm’s experience in implementation of environmental, safety, and health plans related to the transportation and disposal of chemical and biological agent contaminated waste.

Only one response was received.

1. Veolia Environmental Services Technical Solutions (VES) Veolia’s submittal provides numerous examples of their direct experience with the management and disposal of chemical and biological agent contaminated hazardous waste. They have demonstrated their understanding of the topic by detailing all of the requirements that the Army requires for the Safety Plan and other procedures that are required. From the submittal, it is clear that they understand the Army’s technical requirements for the packaging, transportation, and treatment of chemical agent contaminated waste. Their discussion of the necessity for frank and open communication with regulators and community leaders shows their appreciation for the "notorious" nature of chemical agent waste and the extra attention it therefore requires. They have also provided a detailed discussion of their destruction technology located at Port Arthur, Texas, which demonstrates that they have direct responsibility for the treatment of the waste and that they understand the operational parameters necessary to ensure complete destruction.

Veolia has direct experience with disposal of chemical agent contaminated waste at levels > 1 VSL; disposal of hydrolysate, the by-product resulting from the neutralization of chemical agent, and chemical agent precursors as demonstrated by their work on the Syrian Stockpile.

Besides chemical agent waste, Veolia has provided work experience with other notorious waste to include Select Agent Biological waste, such as Ebola and ricin waste. This further demonstrates their ability to deal with highly toxic, specialized waste.

Veolia’s response to the RFI meets the requirements defined in the RFI and is considered a viable option. Additionally, Veolia has conducted work under three previous contracts with this office, DEVCOM CBC. During that time, Veolia has had over 18 years of experience with managing and destruction of our waste with no incidents.

DEVCOM CBC is partnered with the EPA by disposing of the same type of hazardous waste for the EPA. Through ongoing market research, DEVCOM CBC has learned that VES’s Port Arthur site is the only location in the country that has the permits and the capability of incinerating this waste without opening the containers. The RFI was specific, because DEVCOM CBC is required by law (as described above) to dispose of the waste by incineration without being opened due to the health risks and hazards.

b. VES has been awarded sole source contracts since at least 2007 with CMA and DEVCOM

CBC.

9. Interested Sources:

First RFI, 12 October 2022 to 15 November 2022:

1) Bear Environmental

2) Paragon Professional Services

3) Clean Harbors

4) VES

Second RFI, 26 January 2024 to 5 February 2024:

1) VES

10. Other Facts:

a. Procurement history.

Contract Number W911SR-07-D-0011 Awarded 10 September 2007 Treatment and Disposal of Secondary Hazardous Waste for CMA Awardee: Veolia ES Technical Solutions, Lombard, IL Ceiling: $49,000,000.00

Contract W911SR-07-D-0011 with VES for the disposal of hazardous waste was awarded on an other than full and open competition basis under the authority of 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.

Contract Number: W911SR-11-D-0007 Awarded: 26 September 2011 Treatment and Disposal of Secondary Hazardous Waste for CMA

Ceiling: $631,950.00

Contract W911SR-11-D-0007 with VES for the disposal of hazardous waste was awarded on an other than full and open competition basis under the authority of 10 U.S.C. 2304(c)(1) (now renumbered 10 U.S.C. 3204(a)(1)) as implemented by FAR 6.302-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. This contract was intended to serve as a "bridge" contract that would allow the continuation of services until a follow-on contract for the disposal of highly hazardous waste can be awarded.

Contract Number: W911SR-18-D-0010 Awarded: 31 August 2018 U.S. Army Edgewood Chemical Biological Center (ECBC) Hazardous Waste Management Contract

Ceiling: $88,993,060.00

Contract W911SR-18-D-0010 with VES for the disposal of hazardous waste was awarded on an other than full and open competition basis under the authority of 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.

b. Other facts The EPA is the agency responsible for providing the permits. They delegate the responsibility to the individual states. There are two permits which are required for the level of hazardous waste for this requirement- RCRA RCRA Hazardous Waste Permitting Program ensures the safe management of hazardous wastes. Under this program, EPA establishes requirements regarding the treatment, storage, and disposal of hazardous wastes. The permitting program is important to the cradle-to-grave management system for hazardous wastes, which prevents dangerous releases and avoids costly Superfund cleanups. The second permit the facility also operates under is a Clean Air Act (CAA) permit which oversees air emissions associated with the facility’s operations. Permits are issued by authorized states or EPA regional offices. States and EPA cooperate to implement RCRA CAA permitting programs designed to carry out the goals of the Act. Some of these programs are directly implemented by EPA through its Regional Offices but most are carried out by states, local agencies, and approved tribes.

In 2017, DEVCOM CBC inquired about the ability to add this requirement to the Aberdeen Proving Ground (APG) contract for post-wide hazardous waste disposal. They were notified via letter from the Research, Development and Engineering Command (RDECOM), dated 19 December 2017, that the CBARR requirement cannot be included in the APG waste disposal contract for the following reasons: (1) The APG contract scope is for Garrison mission only and the CBARR requirement is for the Garrison mission and global requirements; and (2) The APG contract scope is for traditional hazardous waste, which does not include CBARR’s types of hazardous waste tasks.

11. Technical Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Typed Name: Amy Dean Date:

Title: Project Engineer Signature:

DEAN.AMY.L.123 Digitally signed by DEAN.AMY.L.1230141211

0141211 Date: 2024.02.08 08:57:28 -05'00'

12. Requirements Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Typed Name: Brian O’Donnell Date:

Title: Chief, Project Development Team Signature:

MES.JR.1229284068

Digitally signed by

ODONNELL.BRIAN.JAMES.JR.1229

284068 Date: 2024.02.08 08:11:36 -05'00'

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable.

To support this determination, various cost analysis and price analysis techniques will be used, including comparison with than IGE as well as the use of Certified Cost or Pricing Data.

Typed Name: Nicholas Granata Jr. Date:

Title: Contracting Officer Signature:

GRANATA.NICHOLAS.JR.1388016

Date: 2024.02.07 18:15:29 -05'00'

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Typed Name: Nicholas Granata Jr. Date:

Title: Contracting Officer Signature:

GRANATA.NICHOLAS.JR.13880166

Date: 2024.02.07 18:16:10 -05'00'

ODONNELL.BRIAN

GRANATA.NICHOL

AS.JR.1388016651

GRANATA.NICHOL

AS.JR.1388016651

APPROVAL

Based on the foregoing justification, I hereby approve the procurement of support related to the treatment and disposal of hazardous waste from the treatment of various chemical agents and/or biological agents on an other than full and open competition basis pursuant to the authority of 10 U.S.C. 3204 (a)(1), as implemented by FAR 6.302-1(a)(2), subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for this acquisition.

Signature:

MOYER.DANIEL

LE.M.124970515

MOYER.DANIELLE.M.12497051

Date: 2024.02.14 17:39:03 -05:00

Date:

DANIELLE M. MOYER Title: Senior Contracting Official