JOFOC 80KSC023DA010 Mod P00022.pdf

Rev.: 10/2025

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

John F. Kennedy Space Center (KSC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

For Sole Source Acquisition of Liquid Helium (LHe) and Lease of LHe Pumps for

KSC/80KSC023DA010

1. Federal Acquisition Regulation (FAR) 6.104-1(a)(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) KSC.

The procuring agency is the NASA, and the contracting activity is KSC.

2. FAR 6.104-1(a)(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 an extension to contract number 80KSC023DA010 NASA/KSC Sole Source Supply of LHe and LHe Pump Lease for an additional five years from November 1, 2026, to October 31, 2032. The current contract is a sole source with Air Products and Chemicals, Inc. (APCI), Allentown, PA, and provides bulk LHe and the lease of six LHe pumps to KSC in support of the Converter Compressor Facility (CCF) operations and gaseous helium (GHe) supply pipeline. The current contract was executed when the Bureau of Land Management was no longer providing helium, and market prices were high due to various global events. The Agencywide LHe contracts, recently awarded, reflected much lower prices than previous Agencywide LHe contracts, and this KSC sole source contract.

Based on this recent data, NASA KSC requested a reduction in helium unit prices from APCI, to which APCI would only agree if the contract’s Best Estimated Quantities were reduced. NASA KSC would not agree.

As a result of the above, research was conducted to find an alternative solution. A Request for Information (RFI) was published to the Government Point of Entry (GPE) website (SAM.gov) on August 22, 2025, to determine if other helium pumping and compression equipment was available. The RFI requested industry insight on ways to increase, or improve upon, its primary method of obtaining high-pressure helium to support KSC and Cape Canaveral Space Force Station (CCSFS) operations. Two responses were received on the response due date of September 22, 2025. The responses received were from APCI and Spaceline Technologies, Inc. (Spaceline). Technical Evaluation of the two responses determined that the alternative proposed by Spaceline did not meet the specified requirements in the RFI, particularly for inlet pressures for compressors, and was therefore, technically unacceptable.

Rev.:10/2025

Subsequently, APCI agreed to a substantial reduction in price if NASA agreed to extend the current contract by five years. This contract modification proposes to extend the contract period of performance by five years as five one-year option periods with reduced unit prices.

3. FAR 6.104-1(a)(3) – A description of the supplies or services required, to meet the Agency’s needs (including the estimated value):

NASA/KSC has a requirement for the continued delivery of bulk LHe in tankers to the CCF at KSC, and the lease of six LHe pumps to support a range of activities at KSC and CCSFS.

LHe is converted to GHe through a pressurization process using an APCI proprietary LHe pump located at the CCF. The high pressure GHe is in turn pumped into the KSC GHe pipeline and is distributed and utilized by NASA and almost all commercial partners at KSC and CCSFS. Various facilities supported by the KSC high pressure GHe distribution pipeline include Launch Complex 39B, as well as CCSFS space launch complex SLC-41, and SLC-

36. GHe is used as an inert purge gas for hydrogen systems and as a pressurizing agent for ground and flight fluid systems. Helium is also used for spacecraft and launch vehicle processing, launch operations, and as a cryogenic cooling agent. To support this continuing requirement, a five-year contract extension is anticipated through the addition of five, one-year option periods as follows:

Option Period 1: November 1, 2027 – October 31, 2028 Option Period 2: November 1, 2028 – October 31, 2029 Option Period 3: November 1, 2029 – October 31, 2030 Option Period 4: November 1, 2030 – October 31, 2031 Option Period 5: November 1, 2031 – October 31, 2032

The estimated LHe quantity for the contract extension is 33,033,400 liters.

The estimated total contract extension value is $870M.

4. FAR 6.104-1(a)(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.

3204(a)(1), as implemented by FAR 6.103-1, “Only one responsible source and no other supplies or services will satisfy agency requirements”.

5. FAR 6.104-1(a)(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. 3204(a)(1) is there is only one responsible source, and no other supplies or services will satisfy agency requirements as described below.

The purpose of the LHe pumps is to convert LHe to GHe, which is then pumped into the KSC GHe pipeline and delivered to distribution points throughout KSC. In early 2020, a requirement was identified to lease six LHe pumps to support Artemis/Space Launch System

(SLS) launches and to replace the then aging LHe pump and obsolete gas compressors. Six pumps were obtained through APCI as a sole source lease under the current contract. One additional pump has been leased from APCI since 2015 and is intended to serve as a backup for the six-pump system. Recognizing that helium recently purchased through an Agencywide contract is priced lower, NASA/KSC wanted to obtain similar pricing through the current sole source arrangement. APCI would only consider lowering prices if NASA/KSC agreed to lower the Best Estimated Quantities (BEQs), which initially could not be accomplished based on projected needs. APCI was technically identified to have the only operational LHe pump known to meet the required performance criteria, including peak pressure and flow rate, to support launches. The pumps are not available for purchase and can only be leased through APCI. As part of both its technical and business case, APCI conditioned the lease of its proprietary LHe pumps to NASA on whether APCI also supplied all of the helium to be utilized by the pumps. Through discussions with APCI, APCI made it clear that it would only agree to lease the LHe pumps if it retained the right to cancel the pump lease agreement and remove its pumps if NASA procured helium from another source to utilize in APCI’s proprietary LHe pumps. Prior to the execution of the current contract for LHe and the six pump lease, KSC Senior Management agreed that there were no other alternatives to the APCI LHe pumps that met NASA’s requirements, and that to maintain the capability of delivering of GHe through the pipeline, KSC would need to enter into a sole source contract with APCI for both LHe and the lease of the six pumps, which are used to support the SLS launches. Additional market research was conducted in August 2025 to confirm that APCI’s proprietary pumps are the only available option on the market capable of meeting NASA’s requirements (see Section 2 above).

6. FAR 6.104-1(a)(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 part 5 and, if not, which exception under part 5 applies:

A notice to SAM.gov was published on January 26, 2026, in accordance with FAR part 5.

This posting informed potential sources of NASA/KSC’s intent to award this sole-source extension modification to APCI. The notice also stated that interested companies may submit their capabilities and qualifications to perform the effort and that these capabilities/qualifications would be evaluated solely for the purpose of determining whether or not to conduct this acquisition on a competitive basis. Responses to this notice are due by February 11, 2026. The Government did not receive any responses (see Section 10 below).

7. FAR 6.104-1(a)(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 must 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. In accordance with FAR 15.404-1(b), the CO will compare proposed pricing to: 1) the current contract between NASA/KSC and APCI; 2) the current Agencywide LHe contracts; 3) the Independent Government Cost Estimate; and 4) the

Defense Logistics Agency published current standard prices for aerospace products at https://www.dla.mil/Energy/Business/Standard-Prices/.

8. FAR 6.104-1(a)(8) – Description of the market research conducted, and the results, or a statement of the reason market research was not conducted (e.g., urgent, and compelling requirement):

On August 22, 2025, NASA KSC published an RFI to the GPE website SAM.gov to determine if other helium pumping and compression equipment was available in the market.

The results of this market research are documented in Section 2, paragraph 3 above.

9. FAR 6.104-1(a)(9) – Any other facts supporting the use of other than full and open competition:

The KSC bulk LHe to GHe conversion system and the CCF capability that supplies the GHe into the pipeline is a launch critical element supporting space launch operations. It would not be possible to conduct launch operations without it. The GHe provided through the CCF is at very high pressure (~6000 psi) and flow rates (~1500-1800 scfm) required by the space launch operations that it supports.

All known high pressure LHe pump requirements at KSC/CCSFS have been supported exclusively by proprietary APCI LHe pump systems. The only other current user of APCI LHe pumps are the launch facilities at Vandenburg Air Force Base (VAFB), which is similarly obligated to obtain the LHe commodity that runs through the LHe pumps from

APCI.

Prior to the integration of the leased LHe pumps from APCI at the CCF, conventional gas compressors were exclusively utilized. However, these aging compressors (some dating to the 1960s) have required significant increases in maintenance and are becoming obsolete.

The Agency decision discussed in this paragraph and also outlined in Section 5 above took into consideration investment costs, life cycle costs, energy costs, and operations and maintenance costs to determine how best to upgrade the CCF to support the required increased GHe needs. As a result, it was determined that an upgrade to new conventional gas compressors would require significantly higher energy, operations and maintenance costs, and would require substantially increased facility space in comparison to being able to obtain the same flow capability utilizing LHe pumps. The LHe pumps would fit into the proposed new footprint of the CCF, require less energy, and APCI would be responsible for the maintenance costs. As a result, the use of LHe pumps was considered the best option for future Artemis/SLS and other Spaceport support. This fact-based decision to utilize APCI leased LHe pumps in the upgraded CCF has driven the requirement for the sole source acquisition of LHe from APCI.

10. FAR 6.104-1(a)(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 part 5 (See Section 6 above). Responses from interested companies were due February 11, 2026, and no responses were received.

11. FAR 6.104-1(a)(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 Agency continually attempts to overcome barriers to competition by surveying the market to determine if new sources are available that are capable of meeting requirements, and by re-evaluating existing requirements to determine if modifications can be made that will increase competition. However, the knowledge and expertise of APCI, coupled with the lack of proven operational systems from any other known source does not currently lend itself to this goal. Prior to any future acquisition for the same requirement, an assessment will be made whether replacing the existing APCI LHe pumps and competitively procuring the LHe will be in the best interest of the Government.

Rev.: 10/2025

Sole Source Acquisition of Liquid Helium (LHe) and Lease of LHe Pumps for

KSC/80KSC023DA010

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIGNATURE PAGE

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

Nicole Dhanraj Technical Representative

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

Rose Dougherty Contracting Officer

CONCURRENCES:

Edwin Martinez, Procurement Officer, Competition Advocate, Head of Contracting Activity, Kennedy Space Center

NICOLE

DHANRAJ

Digitally signed by

NICOLE DHANRAJ

Date: 2026.02.13 09:55:06 -05'00'

Rose Dougherty

Digitally signed by Rose Dougherty Date: 2026.02.13 10:10:39 -05'00'

Edwin Martinez

Digitally signed by Edwin Martinez Date: 2026.02.13 13:42:09 -05'00'

Sole Source Acquisition of Liquid Helium (LHe) and Lease of LHe Pumps for KSC

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIGNATURE PAGE

Office of the General Counsel at Headquarters

Geoffrey Sage Agency Competition Advocate

APPROVAL:

Marvin Horne Senior Procurement Executive

Young Cho Digitally signed by Young Cho Date: 2026.02.12 09:40:23 -05'00'

GEOFFREY

SAGE

Digitally signed by GEOFFREY

SAGE

Date: 2026.02.13 20:51:48 -05'00'

GEOFFREY

SAGE

Digitally signed by GEOFFREY

SAGE

Date: 2026.02.13 20:52:13 -05'00'

For