JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

in accordance with FAR Subpart 6.302-1

This document is being prepared pursuant to the content requirements prescribed in Federal AcquisiƟon RegulaƟon (FAR) Subpart FAR 6.303-2(b).

1. FAR 6.303-2(b)(1), IdenƟficaƟon of the agency and the contracƟng acƟvity, and specific idenƟficaƟon of the document as a "JusƟficaƟon for other than full and open compeƟƟon":

Agency: U.S. Environmental ProtecƟon Agency ContracƟng AcƟvity: Office of Chief Procurement Officer (OCPO)

Office of Land, Enforcement and Air Division (LEAD)

Program Office: Office of Land and Emergency Management (OLEM)

Office of Emergency Management (OEM)

Program POC: Stuart Willison, OLEM/OEM

Project IdenƟficaƟon: 68HERH25C0005: Portable High Throughput Integrated Laboratory

IdenƟficaƟon Systems (PHILIS) Plaƞorm ModernizaƟon, Change Order

Proposed Source(s): MRIGLOBAL (UEI: HKQHNFKNKL15)

2. FAR 6.303-2(b)(2), Nature and/or descripƟon of the acƟon being approved:

The purpose of this jusƟficaƟon is to increase the capacity (i.e., ceiling) of EPA’s contract, 68HERH25C0005, with MRIGLOBAL by $244,900.00. This increase is necessary to account for changes required for requirement expansions, in labor and other direct costs that have caused variances outside the current ceiling price. The aforemenƟoned changes do not impact the scope of the contract but represent an approximately 1.8% increase to the current $13,568,279.00 ceiling of the contract.

3. . FAR 6.303-2(b)(3), A descripƟon of the supplies or services required to meet the agency’s needs (including the esƟmated value):

The United States Environmental ProtecƟon Agency’s (EPA) Office of Land and Emergency Management (OLEM), Office of Emergency Management (OEM), Chemical, Biological, Radiological, and Nuclear Consequence Management Advisory Team (CMAT) is one of EPA’s four (4) Special Teams, which were designed to provide general and specialized capabiliƟes during emergency responses, Ɵme criƟcal responses, and non- Ɵme criƟcal responses. CMAT’s mission is to prepare for and support the removal and remedial response community 24/7/365 during all hazards to protect human health and the environment. The PHILIS laboratory systems were designed to detect Chemical Warfare Agents (CWAs) and Toxic Industrial Chemicals (TICs). MulƟmedia VolaƟle Organic compound (VOC) and Semi-volaƟle organic compound (SVOC) analysis is performed in the laboratories as well as other analyses as needed.

The PHILIS Program provides on-site mobile and base of operaƟons laboratory capabiliƟes to respond to CWA and TIC releases, as well as any supplementary locaƟons that are deemed fundamental to accomplishing EPA’s mission. This capability is unique and not replicated by any other government program, federal or state, and is criƟcal to restoring contaminated areas for safe public use aŌer a chemical release.

This increase is necessary to account for changes required for requirement expansions that have caused variances outside the current ceiling price in the amount of $244,900.00. The variances include:

- Custom Generator Exhaust Adaptors – the custom adaptor will couple the generator exhaust outlet to high-temperature ducƟng present for use at the home locaƟons of each laboratory which will push all exhaust outside the building.

- InsulaƟon Upgrade - upgrade from 2” to over-fill and cut flush in all applicable caviƟes, increasing average insulaƟon thickness to ~ 5.5” to ensure all caviƟes are filled.

- Fire Sensing and Suppression system Upgrades - upgrade from surface mounted control and sensor system wire rouƟng to sub-surface rouƟng, installaƟons, and paint raw metal on Unistrut supports for the dispersion components and allows for beƩer facility decontaminaƟon.

4. FAR 6.303-2(b)(4), An idenƟficaƟon of the statutory authority permiƫng other than full and open compeƟƟon.

This JusƟficaƟon for Other Than Full and Open CompeƟƟon (JOFOC) is being issued pursuant to the authority granted by 41 U.S.C.253(c) (1): Only one responsible source and no other supplies or services will saƟsfy agency requirements as implemented by FAR 6.302-1.

5. FAR 6.303-2(b)(5), A demonstraƟon that the proposed contractor’s unique qualificaƟons or the nature of the acquisiƟon requires use of the authority cited.

The nature of the circumstances required to support the raƟonale for using the authority as cited under the previous secƟon, “Only one responsible source and no other supplies or services will saƟsfy agency requirements as implemented by paragraph 6.302-1 of the Federal AcquisiƟon RegulaƟons (FAR)”, is detailed below.

The ContracƟng Officer has determined that the only way to ensure the mission criƟcal design and opƟmizaƟon services performed under 68HERH25C0005 can be completed is to incorporate the changes outlined in MRIGlobals’ Change proposal dated February 18, 2026, into the current contract increasing the ceiling by $244,900.00 for those changes. At this Ɵme, fourteen (14) months into performance, design and fabricaƟon are well underway, with over 90% of the final design of the labs being completed.

Because of the specific knowledge and performance required for the execuƟon of the requirements of the contract, the learning curve would be substanƟal and impracƟcal for a new contractor with over 90% of the design already being completed. Therefore, there are presently no other contractors other than MRIGLOBAL capable of compleƟng the necessary changes to their own design without causing detrimental delays to the program’s ability to ready the labs for restoring contaminated areas for safe public use aŌer a chemical release. A lapse in these criƟcal services would result in the Agency being unable to meet its mission and result in endangerment to the public’s health, welfare and environment.

Bringing in a new contractor at this point, when the design is nearly completed, would require a full review and evaluaƟon of a new firm’s capabiliƟes to ensure the same level of design and opƟmizaƟon support. Therefore, at this Ɵme, increasing the ceiling of 68HERH25C0005 to incorporate the required design changes and accommodate the increased labor and materials to ensure the labs are ready to respond to CWA and TIC releases is the only viable opƟon. Any other approach would likely result in duplicaƟve costs on the Government and contractors’ part that would not be recovered through any savings that might be aƩained through compeƟƟon. There is currently only one source to obtain the specific knowledge and experience necessary to ensure no adverse impact on compleƟng the work currently provided under this contract.

6. FAR 6.303-2(b)(6), A descripƟon of efforts made to ensure that offers are solicited from as many potenƟal sources as is pracƟcable, including whether a noƟce was or will be publicized as required by subpart 5.2 and, if not, which excepƟon under 5.202 applies.

Since this jusƟficaƟon is for an increase to an exisƟng EPA contract (68HERH25C0005), offers will not be solicited from any addiƟonal sources beyond MRIGLOBAL.

As required by FAR 5.201(b) and in accordance with FAR 5.203(a), a noƟce of the proposed contract acƟon requested herein was posted on March 17, 2026 (TBD), at the Government Point of Entry (GPE) (hƩps://www.SAM.gov), and closed April 1, 2026, at 4:30 PM Eastern Standard Time (EST) (TBD). A copy of the noƟce is aƩached hereto and available at:

hƩps://sam.gov/opp/4e7a372ab8134a3389a40d8c72a6d023/view

EPA did/did not receive any responses to the noƟce.

In accordance with FAR 6.305, within 14 days aŌer issuing the modificaƟon to increase the ceiling of 68HERH25C0005, this jusƟficaƟon will be published (i.e., made publicly available) in accordance with FAR

5.301. The jusƟficaƟon will be posted at the Government Point of Entry (GPE) (hƩps://www.Sam.gov), which will provide access to the jusƟficaƟon by linking to the GPE, for a minimum of 30 days. Any responses received to the noƟce will be recorded and retained as a lisƟng of interested and/or prospecƟve sources to be included in EPA’s market research for future OLEM portable laboratory idenƟficaƟon systems and/or modernizaƟons to exisƟng systems

7. FAR 6.303-2(b)(7), A determinaƟon by the contracƟng officer that the anƟcipated cost to the Government will be fair and reasonable:

The exisƟng support currently being performed by MRIGLOBAL under 68HERH25C0005 was compeƟƟvely awarded in accordance with the policies and procedures governing compeƟƟve acquisiƟons under FAR Part 15, ContracƟng by NegoƟaƟon, as supplemented by FAR Part 12, AcquisiƟon of Commercial Products and Commercial Services on January 22, 2025.

At the Ɵme of contract award, the labor and other direct costs, and total anƟcipated cost to the Government were determined to be fair and reasonable. The ContracƟng Officer, in collaboraƟon with the cognizant technical personnel, will ensure that the magnitude of effort and proposed cost for the changes to be incorporated via the proposed contract acƟon will be fair, reasonable, and consistent with commercially available pricing for the changes to be incorporated herein.

8. FAR 6.303-2(b)(8), A descripƟon of the market research conducted (see part 10) and the results or a statement of the reason market research was not conducted:

No market research was conducted for this proposed acƟon because this acƟon is intended to be issued as a change order against 68HERH25C0005 as permiƩed by and in accordance with FAR 6.302-1.

9. FAR 6.303-2(b)(9), Any other facts supporƟng the jusƟficaƟon:

No addiƟonal facts are required to support this jusƟficaƟon beyond those documented above. The acquisiƟon file contains sufficient informaƟon to support the determinaƟon that the proposed acƟon saƟsfies the requirements of FAR 6.303-2.

10.FAR 6.303-2(b)(10), A lisƟng of the sources, if any, that expressed, in wriƟng, an interest in the acquisiƟon:

No responses were received in response to the noƟce of the proposed contract acƟons.

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

No barriers to future compeƟƟon exist, as this contract was awarded resulƟng from an unrestricted, full and open compeƟƟon, and any future similar requirement is also intended to be procured uƟlizing unrestricted compeƟƟve procedures. Since this jusƟficaƟon is requesƟng a sole-source increase to the exisƟng contract, 68HERH25C0005, a proposal will not be solicited from any addiƟonal sources beyond MRIGLOBAL to incorporate the changes and increased cost of performance as a result of those changes.

12. FAR 6.303-2(b)(12), ContracƟng officer cerƟficaƟon that the jusƟficaƟon is accurate and complete to the best of the contracƟng officer’s knowledge and belief:

I hereby cerƟfy that this jusƟficaƟon is accurate and complete to the best of my knowledge belief.

Adrianne Wells ContracƟng Officer Land, Enforcement, and Air Division (LEAD)

13. FAR 6.303-2(c). Evidence that any supporƟng data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or schedule requirements or other raƟonale for other than full and open compeƟƟon) and which form a basis for the jusƟficaƟon have been cerƟfied as complete and accurate by the technical or requirements personnel:

The undersigned hereby cerƟfies that all supporƟng data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other raƟonale for other than full and open compeƟƟon) and which form a basis for this jusƟficaƟon is complete and accurate:

Stuart Willison ContracƟng Officer RepresentaƟve (COR)

14. APPROVAL: In accordance with FAR 6.304(a)(1) and EPAAG 1.6.1-A, Item 8b for acƟons within the thresholds set forth in FAR 6.304(a)(1):

Heather Adams Supervisory ContracƟng Officer – SecƟon Manager Land, Enforcement, and Air Division (LEAD)