Limited_Sources_Justification_140P2126F0022_Redacted_1.pdf

United States Department of the Interior Limited Sources Justification under FAR 8.405-6(a)(1)

A. Background and description of the action The National Park Service (NPS) complies with environmental laws and regulations related to a variety of contaminated sites matters in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the Resource Conservation and Recovery Act (RCRA), Clean Air Act (CAA), Clean Water Act (CWA), and analogous State and local laws to ensure that park unit operations and activities comply with the NPS Organic Act, are protective of human health and the environment, to avoid violations, and to reduce the risk of causing environmental harms, including creating new contaminated sites.

This acquisition is for the logical follow-on to the original technical support services order 140P2125F0201 (awarded September 29, 2025) to Jacobs Engineering Group, Inc. (Jacobs) for additional technical services on the on East Potomac Park (EAPO) Soil Storage Project. The EAPO Soil Storage Project includes the transport of tons of soil excavated from below the former East Wing, which is being stockpiled at the golf course.

The technical support services for the EAPO Soil Storage Project are primarily to provide onsite monitoring of the daily import of materials, collect stockpile samples for laboratory analysis of contaminants, and document preparation with data tabulation and analysis with relevant screening levels. The support for the EAPO Soil Storage Project is ongoing and the import of material is anticipated to continue for an additional 18 to 22 weeks, at the current rate of trucking. In addition, there will be several activities to provide technical support through additional sample collection (including drilling methods), surveying, document preparation, ecological risk assessment, and other activities, some of which will be dependent upon the analytical results of samples collected. This order will have two option years for similar services after the base period. The order will include a mix of labor hour (LH) and time-and-materials (T&M) tasks.

The Jacobs team has been exclusively responsible for NPS environmental technical support at the EAPO Soil Storage Project since October 24, 2025, however Jacobs’ current task order for the EAPO Soil Storage Project only authorized monitoring and sampling through January 31, 2026. NPS has determined that the most efficient and economic option is to have Jacobs continue to perform the work, whose costs may exceed $ .

B. Justification

1. Circumstances FAR 8.405-6(a)(1)(i) lists three circumstances justifying limiting the source solicited for a proposed order, including Paragraph (C): “In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited sources procedures.”

NPS has five active BPAs with Federal Supply Schedule / Multiple Award Schedule contractors for CERCLA and contaminated site cleanup work. After a competitive process in which the five BPA contractors were given a fair opportunity to compete for the work, Jacobs Engineering Group, Inc. (Jacobs) was awarded order 140P2125F0201 on September 29, 2025, to provide site-specific cleanup support to contaminated sites funded through the Department of the Interior’s Central Hazardous Materials Fund (CHF) and the National Park Service’s Environmental Management Program (EMP) funds. On October 24, 2025, Jacobs began providing technical support (sample collection and truck monitoring over a four week period) for the EAPO Soil Storage Project. As the needs of the project evolved, additional tasks were also assigned to Jacobs and the need to extend the original length of the sample collection and truck monitoring period were identified.

Other tasks such as formally documenting the sampling methodology, data quality objectives, evaluating the contaminant data, and conducting screening level risk assessments were not included in the originally assigned tasks due to budgetary and schedule constraints; however, these tasks will be needed to complete the project. Additionally, once the sampling results are received technical support for additional sample collection, potentially using drilling methods, surveying, additional ecological risk assessment, and other tasks may be required.

The Jacobs team has been exclusively responsible for all sample collection and import monitoring at the EAPO Soil Storage Project, except for the first week when monitoring was conducted by NPS staff. The work is a logical follow-on to the original order and the most efficient and economic option is to have Jacobs continue to perform the work.

2. Market Research and Other Capable Sources Market research indicated that other potential sources include the five Contaminated Site Cleanup Blanket Purchase Agreement (BPA) contractors, which are listed as a recommended source in NPS policy AP&P 1443.08-01, Mandatory and Recommended Contracts; GSA Multiple Award Schedule (MAS) 541620 contractors in a variety of socioeconomic categories;

and the open market, using a set-aside or sole source under a socioeconomic program.

3. Barriers to Future Competition Most of the contracted technical support is competitively solicited from the five BPA contractors. Other firms in the cleanup BPA pool could compete for similar work at this site in the future, if NPS still has a need for contracted support. The biggest challenges for a new contractor would be the expedited scheduling requirements for providing field staffing to support ongoing monitoring requirements for the import of materials, the rationale for the variations in contaminant sampling design due to observed changes in the import material, and the complex evolution of current and future NPS compliance obligations. There are not systemic barriers to competition for subsequent acquisitions.

C. Recommendation and Certification by Program Office. Based on the above justification, I recommend this acquisition be conducted using limited sources procedures described in FAR Part

8. I certify that the technical portions of this justification are accurate and complete.

//SIGNED// Program / Project Manager

D. Contracting Officer Certification and Approval. I certify that this justification is accurate and complete to the best of my knowledge and belief and determine that award to Jacobs Engineering Group represents the best value.

//SIGNED// Contracting Officer

E. Concurrence by Chief of the Contracting Office (required for awards with anticipated value between $350,000 and $750,000 per NPS policy)

//SIGNED// Chief of the Contracting Office