Redacted Limited Sources Justification TO 03.27.2025 Final.pdf

Limited Sources Justification Project Enhancement Corporation 89233119FNA400238 Page 1

LIMITED SOURCES JUSTIFICATION

NATIONAL NUCLEAR SECURITY ADMINISTRATION

OFFICE OF SECURE TRANSPORTATION

GSA Contract NO. GS-00P-0004T ORDER NO. 89233119FNA400238

FEBRUARY 13, 2025

I. AGENCY IDENTITY AND CONTRACTING OFFICE

The United States Department of Energy/National Nuclear Security Administration’s (DOE/NNSA) Office of Secure Transportation (OST) plans to contract for training support services by using an authority for limited sources. The contracting activity is the NNSA Office of Partnership and Acquisition Services, Contracting Operations Division

(NA-PAS-31).

II. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

The purpose of this action is to modify Order 89233119FNA400238 to extend the training support services currently being provided by Project Enhancement Corporation (PEC), 20300 Century Blvd Ste 175, Germantown MD 20874, for twelve months starting August 17, 2025 through August 16, 2026. The original Order was awarded to PEC (GSA FSS Schedule contract No. GS-00P-0004T) under the DOE/NNSA Technical Engineering, and Programmatic Support Services II (TEPS II) Blanket Purchase Agreement (BPA).

OST is responsible for the safe and secure transportation of the Nation’s nuclear weapons, nuclear weapon components, and special nuclear materials throughout the continental United States. This mission requires contracted training support services to include but not limited to essential specialized training and curriculum programs intended to enhance OST’s Federal Agents (FA) ability to prevent the theft, sabotage, or takeover of nuclear weapons, special nuclear materials, and weapons components.

The specialized training comprises basic, advanced, and sustained training which exposes the FAs to a series of controlled, repetitive, and reality-based scenarios that test the limits of their cardiovascular endurance, stamina, strength, eye-hand and body coordination, visual identification (depth perception, night vision), and reaction time. It is through this specialized training that the FAs develop the necessary knowledge, skills, and tactical leadership abilities to detect, mitigate, and/or eliminate potential threats to the classified shipments under their protective custody and to use deadly force if needed to enforce the laws that pertain to the security protection of the classified shipments pursuant to Section 161 k of the Atomic Energy Act of 1954, as amended by Pub. L. 105-394 (codified at 42 U.S.C. 2201(k)). The training is critical in ensuring that the FA Force maintain a high capability and tactical proficiency while ensuring the safety and security of the transportation of the Nation’s nuclear weapons, special nuclear materials, and weapons components.

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III. DESCRIPTION OF SUPPLIES AND/OR SERVICES

To carry out its mission, OST operates three Federal Agent Operations Commands: (1) Agent Operations Western Command, located in Albuquerque, New Mexico; (2) Agent Operations Central Command, located in Amarillo, Texas; and (3) Agent Operations Commands Eastern Command, located in Oak Ridge, Tennessee.

OST also operates a primary Training Command (TRACOM) located at Fort Chaffee, Arkansas. In this case, PEC provides OST with critical training support as it pertains to Instructors (Type I, II, Drive, and Adjunct), Training Assistant Support at TRACOM/AOCs, Fitness Coordinators, Exercise Control Center (ECC) Support;

Environmental Safety and Health (ES&H) Coordinator, and the Curriculum Development/Instructional Systems Designers at TRACOM and OST-HQ.

Based on the training activities, PEC’s support to OST is critical since OST historically averages over 100 training weeks annually. Specifically, training is completed January through December each year. The largest of the OST core training programs is the Federal Agent Candidate Training (FACT). FACT is 19 weeks and is required for Federal Agents to perform operational missions. The course is run three times per year. Continuity of training operations is critical for ensuring all goals and objectives are met safely, consistently, and effectively utilizing a core cadre of training instructors. There are two separate overlaps of FACT courses each year. These overlaps occur each year in April-May for seven weeks and in July-August for six weeks. The course beginning in August graduates in November 2025.

In addition, there is a large-scale training event (Reality Based Assessment

(RBA)) scheduled beginning September 12-20, 2025. This RBA training event encompasses multiple commands within OST and requires immediate action to secure dates, make arrangements and execution to continue mission essential requirements.

Accordingly, this RBA training event needs to take place during September and in order to do so, coordination and securing of dates for the event need to be accomplished now to avoid unavailability of required facility accommodations, areas, functions and OST command projected training events.

The total anticipated value of this Order extension is approximately

$9,882,835.00.

IV. LIMITED SOURCES AUTHORITY

The statutory authority permitting limiting sources as implemented by the Federal Acquisition Regulation (FAR) is Subpart 8.405-6(a)(1)(i)(C) which allows the agency to limit sources on a proposed order or BPA exceeding the micro-purchase threshold where “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.”

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This original requirement was competed among the TEPS II BPA holders and awarded to PEC. The work that will be performed under this extension is a continuation of the services provided under Order 89233119FNA400238. PEC’s experience and current involvement with this requirement positions it as the logical contractor to continue to provide the service support requirements in the short-term. PEC has staff with the appropriate clearance levels and qualifications in place to continue to support the requirement. This allows PEC to secure arrangements and coordination for critical FAs qualifications and training events without delays that would result in negative impacts across the OST commands preventing future scheduled training events and certifications to occur. The loss of PEC training support would be detrimental to the OST mission. OST lapse in training or sufficient training may result in not fulfilling the mission with highly trained FAs. This would have a significant impact to mission readiness which then impacts OST’s ability to defend and protect classified shipments from any attack which jeopardizes OST’s national security mission which is to ensure that the US strategic deterrent remains, safe, secure, and effective. Ultimately, this would cause a total disruption to the overall OST commands training event schedule and thus increase risk to the FA’s ability to be prepared to carry out its responsibility to prevent theft, sabotage, or takeover of the nuclear weapons, special nuclear materials, and weapons components.

Competing the short-term action would result in duplication of costs and effort, as well as potentially cause unacceptable delays in meeting the current requirements, as a new contractor would require time for onboarding, credentialing, and transition.

Extending the current Order is the interest of economy and efficiency and also in the best interest of the Government.

V. CONTRACTING OFFICER DETERMINATION OF BEST VALUE

The Contracting Officer (CO) has determined after considering the level of effort and the mix of skills available for the tasks needed, that the proposed action represents a reasonable total price and will be the best value for the Department consistent with FAR 8.404(d). The CO also determined that the estimated price of the Order extension is in line with the current contract prices which were competitively awarded.

VI. MARKET RESEARCH

The CO conducted informal market research in accordance with FAR 10.002 against the DOE/NNSA Enterprise-Wide Technical and Engineering, and Programmatic Services (TEPS) III BPA to determine if there are multiple small businesses who can fulfill the requirement. The CO reviewed the vendors under the TEPS III BPA, vendors who have an associated applicable NAICS code 541611-Administrative Management and General Management Consulting Services, and their GSA Schedules to determine if same or similar labor positions are available as those identified within the current Order Performance Work Statement (PWS). The informal market research analysis shows there are multiple small business vendors who potentially could have the

Project Enhancement Corporation 89233119FNA400238 Page 4 capability to perform the required services. However, this will not be fully known until a Request for Information (RFI) is released to the TEPS III BPA Holders to assess vendors capabilities based on the anticipated revised scope of work. For this short-term requirement, no other vendor would be able to immediately meet the agency’s needs without potential schedule and performance risks.

For the follow-on longer term effort, the Government has full intent to issue an RFI and compete the requirement amongst capable small businesses under the TEPS III BPA to foster and support small business opportunities.

VII. OTHER FACTS

None.

VIII. STEPS TO FOSTER COMPETITION

As discussed under paragraph VI, Acquisition Planning for the follow-on effort is ongoing. Prior to the completion of the logical follow-on services, NNSA intends to competitively solicit and award a longerterm contract for the required services.

IX. TECHNICAL OR REQUIREMENTS PERSONNEL CERTIFICATIONS

Acquisition Initiator/Technical Representative:

I certify that the facts and representations under my cognizance, which are included in this justification, and which form a basis for this justification, are complete and accurate.

Signature Date

X. CONTRACTING OFFICER CERTIFICATIONS

Contracting Officer:

I certify that this justification is accurate and complete to the best of my knowledge and belief.

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Competition Advocate:

I have reviewed this Limited Sources Justification and find it to be accurate and complete to the best of my knowledge and belief. Since this justification does not exceed $15M, this review serves as approval.