Justification for Other than Full and Open Competition FINAL 8_24_2026_Redacted 8_24_2026.pdf

Rev.:4/2026

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

NASA SHARED SERVICES CENTER (NSSC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

for

High Pressure Gas Facility (HPGF) Air Dryer Refurbishment

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 constitutes a Justification for Other Than Full and Open Competition prepared by the National Aeronautics and Space Administration (NASA) for requirements at

John C. Stennis Space Center (SSC).

The procuring agency is NASA, and the contracting activity is the NASA Shared Services

Center (NSSC), Procurement Services Division.

2. FAR 6.104-1(a)(2) – The nature and/or description of the action being approved:

This justification supports the use of other than full and open competition to award a sole‑source contract to Lectrodryer, LLC for the refurbishment of one High‑Pressure Gas

Facility (HPGF) HPB‑600 desiccant air dryer. The action includes returning the unit to full original equipment manufacturer (OEM) certified operational conditions through proprietary refurbishment procedures and installation of OEM specified replacement components.

The refurbishment will include:

• OEM refurbishment of twelve (12) main Globe valves;

• Replacement and upgrade of instrumentation to current Lectrodryer production standards;

• Replacement of desiccant media;

• Refurbishment of the prefilter and scrubber piping sections, including inspection, blasting, and coating;

• Installation of new OEM filter elements, scrubber components, silencer, and electric heater;

• Completion of all required OEM testing and certification to ensure full compatibility with existing NASA HPGF systems.

This action is required to restore mission critical air‑drying capability and ensure continued safe and compliant HPGF operations.

Rev.: 4/2026

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 requires the complete refurbishment of one HPB‑600 industrial dual‑tower desiccant air dryer used within the High‑Pressure Gas Facility (HPGF). The HPB‑600 unit is a mission‑critical system that provides extremely low‑dew‑point compressed air for precision operations supporting manufacturing, propulsion testing, and instrumentation activities.

It is necessary to maintain this system in OEM compliant condition to ensure reliability, quality control, and safe operations.

The required services include OEM inspection, repair, replacement, refurbishment, and recertification of all components necessary to restore performance in accordance with

Lectrodryer’s proprietary specifications. The estimated value of this acquisition is with an anticipated period of performance of 30 weeks.

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 6.302-1, 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 use of 10 U.S.C. 3204(a)(1), “Only One Responsible Source,” is justified because only

Lectrodryer, LLC is the original equipment manufacturer (OEM) of the HPB-600 dryer and possesses the proprietary technical data, specialized refurbishment processes, and OEM certified replacement components required for successful completion of this effort.

The HPB‑600 contains proprietary design elements and OEM‑controlled assemblies, including Globe valves, instrumentation configurations, and custom‑fabricated piping, that can only be serviced or replaced using Lectrodryer’s certified processes and supply chain. No other vendor has access to the required refurbishment standards, testing protocols, or engineering data needed to ensure system compatibility and safety.

Use of a non‑OEM vendor would result in significant technical, schedule, cost and safety risk to personnel and equipment, due to lack of access to proprietary components and procedures.

Reverse‑engineering or fabrication of non‑OEM parts would extend lead times, increase costs, and jeopardize system certification and operational reliability. Only Lectrodryer can ensure safe and compliant refurbishment in accordance with required OEM performance standards.

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 May 5, 2026, in accordance with FAR Subpart 5.1. This posting informed potential sources of

NASA’s intent to award this sole-source contract to Lectrodryer, 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. The estimated cost is deemed fair and reasonable based on past performance and cost for same/similar services.

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):

An announcement was posted in SAM.gov on May 5, 2026, with responses due May 18, 2026, advising industry of NASA’s intent to award to Lectrodryer, LLC. All responsible sources were invited to submit capability statements. No responses were received.

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

Using a non‑OEM vendor would create significant technical, schedule, cost and safety risks because alternative sources do not have access to the proprietary components, refurbishment procedures, or technical data required to service the HPB‑600 dryer. Lack of access to these

OEM‑controlled materials could lead to improperly refurbished valves, incompatible instrumentation, or unacceptable rework of piping sections. It would also prevent the vendor from meeting required testing and certification standards. Any attempt to reverse‑engineer or substitute non‑OEM parts would extend lead times and drive additional redesign, integration, and verification costs, making such an approach impractical and unsuitable for meeting

NASA’s operational needs.

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 Subpart 5.2 (See Section 6 above) on May 5, 2026, with responses due no later than May 18, 2026. No sources submitted capability statements in response to the synopsis.

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.