JOFOC - B201 SHB Cleanroom MEP Design Services.pdf

Rev.:4/2026

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Johnson Space Center (JSC) White Sands Test Facility (WSTF)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For

CLEAN ROOM HVAC MEP DESIGN SERVICES

FOR THE

BUILDING 201 SHB CLEANROOM ACTIVATION FOR ASTROMATERIALS

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 (JOFOC) prepared by the National Aeronautics and Space Administration (NASA) Johnson Space Center (JSC) White Sands Test Facility (WSTF).

The procuring agency is NASA, and the contracting activity is at JSC WSTF located in Las Cruces, NM.

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 a sole-source contract to Lasco Services for the clean room Heating, Ventilation, and Air Conditioning (HVAC), Mechanical Electrical, Plumbing (MEP) engineering design services in support of the Building 201 South High Bay (SHB) cleanroom activation for astro-materials project.

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):

This procurement is for HVAC MEP engineering design services to support the activation and repurposing of the existing SHB Cleanroom in Building 201 at NASA JSC WSTF, Las Cruces, New Mexico. The total estimated value of this procurement is $90,000, with an estimated design completion date of November 1, 2026.

The purpose of this project is to provide complete engineering design services for the renovation and activation of the existing SHB Cleanroom to support the Agency's backup astromaterials curation mission. The design will include a new cleanroom vault, supporting cleanroom spaces, and a new HVAC system capable of meeting the environmental requirements necessary for long-term astromaterials storage.

Rev.: 4/2026

NASA Procedural Requirements (NPR) 7100.5, Curation of Astromaterials, require that "a portion of every astromaterials collection will be stored and secured in a secondary location as insurance against unexpected loss or damage." Following establishment of a remote storage facility in 1975 and its relocation to the current WSTF facility in 2002, continued expansion of NASA's astromaterials collections has created the time-critical need for additional secure, environmentally controlled storage capacity, particularly for safeguarding of Artemis moon samples. To support this Agency requirement, the NASA JSC Astromaterials Curator's Office has identified the reactivation of the Building 201 SHB Cleanroom as the preferred solution for expanding secondary curation capabilities.

Originally constructed in 2007, the SHB Cleanroom was never fully completed or commissioned and has subsequently been used for general storage. This project will renovate and activate the facility in accordance with current WSTF standards and applicable ISO cleanroom classifications. Upon completion, the facility will provide approximately 848 square feet of certified cleanroom space and 410 square feet of office space, exceeding the minimum programmatic requirements of 500 square feet of cleanroom space and 250 square feet of support space. The renovation also includes construction of a secure vault within the cleanroom and modification of the existing cleanroom ceiling to accommodate the new facility configuration.

As part of the renovation, the existing HVAC systems serving the cleanroom will be completely redesigned, replaced, and revalidated. The design shall include evaluation of the existing Fan Filter Units (FFUs), replacement of all High-Efficiency Particulate Air (HEPA) filters as required, and development of systems capable of achieving and maintaining International Organization for Standardization (ISO) 6 (Class 1,000) cleanroom certification.

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(c)(2)(i), Only one responsible source and no other suppliers or services will satisfy agency requirements without substantial duplication of cost to the Government.

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) as described below.

Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

Over the past twenty-five years, NASA's Johnson Space Center (JSC) Astromaterials Research and Exploration Science (ARES) Division has made a substantial investment in developing, validating, and refining the engineering baseline that supports the Agency's astromaterials curation facilities. Through multiple facility design projects, renovations, commissioning efforts, contamination control studies, and engineering modifications, NASA JSC ARES and Lasco Services have established a highly specialized cleanroom infrastructure that supports the curation of lunar, planetary and other extraterrestrial samples.

This investment extends beyond the physical facilities and includes the accumulation of engineering knowledge, contamination control methodologies, configuration history, design assumptions, operational lessons learned, and validated engineering solutions developed over more than two decades of continuous mission support.

Throughout this period, Lasco Services has worked directly with NASA JSC ARES scientists, contamination control specialists, and facilities engineers to implement the contamination control requirements established by NPR 7100.5, Curation of Astromaterials, NASA contamination control standards, ISO cleanroom requirements, and ARES-specific operational protocols. As a result, Lasco possesses a unique understanding of NASA JSC ARES' contamination control philosophy, approved construction materials, environmental control strategies, cleanroom certification requirements, HVAC system configurations, fan filter unit (FFU) arrangements, building automation interfaces, pressure cascade requirements, and the engineering rationale supporting previous design decisions. Much of this institutional knowledge has been developed through decades of collaboration and practical application and cannot be fully reconstructed from engineering drawings, specifications, or historical project documentation alone.

Lasco Services is the only vendor currently utilized by the Curation team to meet contamination control requirements across NASA’s astromaterial collections. In addition to its extensive experience supporting existing curation facilities, Lasco has been tested and verified as a materials-compliant vendor for the OSIRIS-REx and Hayabusa2 missions through evaluations performed by the Facility Engineering and Curation teams within the ARES Division at NASA JSC. These evaluations confirmed Lasco’s ability to provide cleanroom materials, components, and construction practices that satisfy the stringent contamination control requirements associated with astromaterial curation activities.

The current stainless steel ISO 5 cleanrooms supporting the MMX and Mars2020CK curation activities were constructed by Lasco Services. Maintaining consistency in materials, fabrication techniques, construction practices, and technical knowledge across mission activities is highly desirable and necessary to preserve contamination control performance and configuration continuity. Lasco’s established workflow has consistently delivered cleanroom components that are compatible with NASA JSC ARES material requirements, contamination control standards, and current curation facility practices. This proven capability reduces technical risk by ensuring that future facility modifications and expansions are implemented using the same validated approaches, materials, and engineering methodologies already accepted by the ARES Curation organization.

In addition to its technical expertise, Lasco serves as the engineering steward of the existing design baseline for NASA JSC ARES' astromaterials curation facilities. As the original designer and long-term engineering support contractor for these specialized cleanroom environments, Lasco maintains detailed knowledge of historical design assumptions, approved engineering deviations, contamination control analyses, commissioning activities, and system integration requirements that are essential to maintaining configuration control and engineering continuity across NASA's curation infrastructure. Lasco is extremely knowledgeable of ARES (XI) cleanroom requirements and provides a proven marketplace solution that aligns with existing facility standards, mission needs, and contamination control objectives.

Preserving this continuity minimizes the risk of introducing incompatible design changes, maintains standardized contamination control practices, and ensures long-term operational reliability and maintainability of facilities supporting NASA's astromaterials mission. The continuity of materials, construction methods, and engineering knowledge provided by Lasco is particularly important for facilities supporting sensitive extraterrestrial samples, where even minor deviations from established contamination control practices may introduce unacceptable technical risk.

Requiring a different contractor to perform this effort would necessitate recreating much of this engineering knowledge through extensive review of historical documentation, facility investigations, reverse engineering of prior design decisions, redevelopment of contamination control analyses, and prolonged coordination with NASA JSC ARES subject matter experts. This effort would duplicate more than twenty-five years of engineering development and institutional knowledge already established through NASA JSC ARES' investment in its astromaterials curation infrastructure. Such duplication would constitute a substantial duplication of cost to NASA that is not expected to be recovered through competition and would require significant additional Government technical oversight to validate that a new contractor's design achieves the same level of contamination control, systems compatibility, configuration management, and operational reliability.

Furthermore, the Building 201 SHB Cleanroom Activation project is a critical element of NASA JSC ARES' strategy to expand and modernize the Agency's astromaterials curation capabilities in support of the Artemis campaign and future sample return missions. The time required for a new contractor to acquire decades of specialized institutional knowledge, become familiar with NASA JSC ARES contamination control requirements, and develop an equivalent engineering baseline is incompatible with the accelerated schedule necessary to support Agency mission objectives. Delays associated with qualifying a new engineering contractor would increase technical, programmatic, and schedule risk while jeopardizing the timely activation of this mission-critical facility.

Accordingly, Lasco Cleanroom Services' unique institutional knowledge, proven contamination control performance, configuration management expertise, materials compliance history, and long-standing engineering stewardship of NASA JSC ARES' contamination-controlled facilities constitute unique qualifications essential to satisfying the Agency's minimum requirements. Award to any other source would result in a substantial duplication of cost that is not expected to be recovered through competition and would create unacceptable technical and schedule risks in fulfilling NASA's requirements in support of the Artemis program and future astromaterials missions. Therefore, Lasco Services is the only responsible source capable of providing the required engineering services within the required schedule and with an acceptable level of technical and programmatic risk.

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 Subpart 5.1 and, if not, which exception under 5.101 applies:

A notice to the Government Point of Entry (GPE) website (Sam.gov) was published on July 28, 2026, in accordance with FAR part 5. This posting informed potential sources of NASA’s intent to award this sole-source contract to Lasco Cleanroom Services, LLC. The results of this synopsis are summarized in 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 signature on this document indicates that the contracting officer 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. Proposed pricing for this acquisition will be determined fair and reasonable through comparison of the proposed pricing to an Independent Government Estimate (IGE) completed by the technical team.

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

In an effort to determine potential capable vendors, multiple market research methods were conducted.

NASA evaluated the availability of other engineering firms capable of performing the required services. While several firms possess general MEP engineering capabilities, none demonstrated the combination of specialized experience in NASA astromaterials curation facilities, contamination-controlled cleanroom design, approved material selection, and integration with existing NASA cleanroom systems required for this effort.

During previous NASA procurements supporting the JSC Building 31 Annex cleanroom project, an alternate subcontractor proposed to perform similar work but was unable to satisfy the Agency's contamination control and material restriction requirements. As a result, that firm was determined incapable of meeting NASA's minimum technical requirements.

Lasco Services remains the only contractor with demonstrated experience designing and constructing NASA's existing astromaterials curation cleanrooms, including those supporting current operations and future Artemis sample curation activities.

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

None.

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). The synopsis will be posted on July 28, 2026 and close on August 12, 2026. One company, Constantine Engineering Associates, LLC., responded via email expressing their interest in this effort, and provided their qualifications. NASA reviewed the information and will consider the company for future opportunities.

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 will continue to examine the market in the future for alternative solutions or new sources before executing any subsequent acquisitions for the same requirements.