Limited Source Justification- GSA EMCBC NY NR Tech Support- FINAL.pdf

Limited Source Justification

This acquisition is conducted under the authority of the General Services Award

(GSA) Multiple Award Schedules (MAS) program.

(i) Identification of agency and contracting activity: Department of Energy

Environmental Management Consolidated Business Center (DOE-EMCBC)

(ii) Nature and/or description of the action being approved:

The EMCBC-NY Office is located at the Niskayuna New York, Naval Reactors, Knolls Atomic Power Laboratory (KAPL) site. This office has managed legacy cleanup work related to the characterization, decontamination, dismantlement, demolition, and waste disposition of the Separations Process Research Unit

(SPRU) nuclear facilities at KAPL. In accordance with a Memorandum of

Agreement (MOA) between the Office of Environmental Management (EM) and the Office of Naval Reactors (NR) a partnership was established to utilize EM to perform similar work as that performed for SPRU on behalf of NR primarily for additional excess facilities including defueled reactors at KAPL and the

Kesselring Site (KS).

Under this MOA, EM may undertake environmental remediation activities on behalf of NR. As part of project planning, EM and NR will jointly agree on the radiological and environmental clean-up criteria that will apply to specific projects. These limits will be defined on a project-specific basis. In general, industrial land use cleanup standards will apply for radioactivity. Chemical cleanup criteria will generally be based upon residential land use; however, the presence of water resources may require clean up to a different land use standard.

Alternate cleanup standards may be applied based on existing NR land use plans, EM's agreement to perform clean up to a different land use standard, and other factors, conducted through DOE's authority under the Comprehensive

Environmental Response.

The EMCBC-NY office needs technical support to manage the NR program under this MOA.

(iii) A description of the supplies or services required to meet the agency's needs

(including the estimated value):

▪ Under the general direction of the EMCBC-NY Site Manager (Manager) technical support services include:

o Participation in contractor progress meetings as requested by the Manager o Review and analyze contractor reports, schedules, and related information, and provide summary of review, analysis, and recommendations to the

Manager o Maintain Integrated Master Schedule (IMS) for the NR Program. Update progress based on input from contractors. Include and maintain regulatory and programmatic milestones in the IMS. Modify schedule based on changed conditions and add additional work scope if needed.

o Review and analyze work plans and work packages submitted to DOE for consideration.

• Provide sufficiency analysis of resources, in coordination with technical Subject Matter Experts (SMEs) designated by the Technical

Monitor.

• Provide sufficiency review of proposed schedule.

• Provide qualitative and quantitative analysis of related risk associated with the work package.

• Present review and analysis findings to the Manager.

▪ It is anticipated that this will be a full-time position from January through

September 2022, total value is not expected to exceed $250,000.

(iv) Identification of the justification rationale and, if applicable, a demonstration of the proposed contractor's unique qualifications to provide the required supply or service.

(1) Circumstances that may justify restriction include—Only one source is capable of responding due to the unique or specialized nature of the work.

The government is looking for a contractor with (SME) level qualifications with project controls, scheduling using P-6, and able to review and provide comments on work planning documents to DOE. The government has explored finding expertise for this work previously under the existing

Alaskan-Native American Indefinite Delivery Indefinite Quantity (IDIQ) contract on several occasions however, the contractor has been unable to provide resumes meeting the needed qualifications. Trinity Engineering

Associates (TEA) provides administrative and business function support via their General Services Administration (GSA) contract. Multiple GSA contacts were also surveyed including Pro-2-Serve and MPR. The TEA GSA contract was the only contract surveyed that would include a single individual with the needed SME Level expertise. The other GSA contracts surveyed would required obtaining more than one individual in order to provide the expertise necessary which would increase the overall cost to the government.

(2) An urgent and compelling need exists and following the GSA competitive ordering procedures would result in unacceptable delays.

An urgent and compelling need exists for these services. NR program work has progressed, and several remedial cleanup task orders have been initiated.

In conjunction with NR, EM has been planning for execution of the various projects at KAPL and KS since 2020. Project Controls, Scheduling, and Risk

Management contract support is needed to effectively manage and execute the work. This support was provided previously through a Technical Assistance

Contract that is no longer available, and the position has been vacant since

July 2021. Vendors from alternative technical assistance contracts have been unable to provide a qualified person to provide the needed services. Work is planned to accelerate under the NR program in early 2022 and DOE cannot continue to effectively manage this work without these support services. In accordance with the MOA between EM and NR, EM assumes responsibility for execution of the projects and EM cannot fulfill its responsibilities without this support. Failure to obtain this needed support will result in a delay of field work for D&D and environmental remediation under the NR program.

This task order seeks to engage project controls, schedule and risk expertise to support the EMCBC-NY Federal management team executing the work and

TEA has provided a resume for a person that has the needed qualifications, and who has been working at the KAPL site for over a year supporting other

NR projects.

(v) Consistent with FAR 8.404(d), awarding to TEA represents the best value to the government. Placing the order with TEA will result in the lowest overall cost alternative (considering the price, special features, and administrative costs) to meet the Government’s needs.

Additional GSA contracts were surveyed including Pro-2-Serve, MPR, and TEA.

The TEA GSA contract was the only contract reviewed that would include a single individual with the needed expertise. The other GSA contracts would have required more than person to provide all of the needed expertise. This would increase the cost of the contract and be less efficient. TEA has previously provided a resume that demonstrates all of the required expertise, as well as experience at the KAPL site with one individual at a reasonable rate.

(vi) The Contracting Officer’s Representative did a survey of the market to determine qualified vendors. The COR considered Project Services Group (PSG), Project Time and Cost (PT&C) and MPR. These firms did not have any individuals on their proposed schedules with all of the required expertise and more than one person would have been needed to provide the needed services.

(vii) Any other facts supporting the justification. None.

(viii) The DOE is considering soliciting a single award Blanket Purchase

Agreement with a GSA vendor to remove or overcome the urgent and compelling need to restrict consideration before any subsequent acquisition for the services is made.

(ix) Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government's minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

This justification is certified as accurate and complete to the best of my knowledge and belief.

_________________________ 12/06/2021

Allen Moe, Contracting Officer’s Representative Date

Courtney Stallworth, Contracting Officer Date

12/07/2021