Sole Source Justification - ASCA Final Redacted.pdf

Rev.:4/2026

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

KENNEDY SPACE CENTER (KSC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

NASA NUCLEAR LAUNCH VEHICLE RISK ANALYSIS REPORTS

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 is a justification for other than full and open competition prepared by National Aeronautics and Space Administration (NASA) KSC.

The procuring agency is NASA, and the contracting activity is KSC.

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

This document outlines the rationale for awarding a sole-source Blanket Purchase Agreement (BPA) to Advanced Systems Concepts Associates, Inc. (ASCA) for NASA nuclear launch vehicle risk analysis reports. The risk analysis reports require Event Sequence Diagrams (ESD) to be populated with nuclear-enabled mission specific launch vehicle accident failure scenario and outcome services which characterize risks for all phases of flight. The ESDs deliver essential information on launch vehicle failure mechanisms, the causes, and resulting consequences. This critical analysis supports the characterization of launch failure probabilities, quantification of accident environments, assessment of inertia effects on nuclear payloads, and determination of nuclear material release risks. Additionally, it enables the identification of risk tiering levels in accordance with National Security Presidential Memorandum (NSPM)-20.

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's Launch Services Program (LSP) requires the development of ESDs to assess risk levels for launch vehicles carrying nuclear payloads. For these missions, ASCA provides specialized expertise in NASA launch systems by utilizing confidential, proprietary analytical framework and dataset proprietary to ASCA, that incorporate ESDs populated with nuclear launch vehicle accident failure scenarios and outcomes. Under this BPA, ASCA shall provide all required services and associated support in fulfillment of nuclear missions, such as Space Reactor-1 Freedom (SR-1) launch and future anticipated nuclear missions (lunar missions). Due to the missions being nuclear, it is critical to obtain accurate data to characterize the launch vehicle for multiple reasons, including enabling more robust safety and risk analyses related to site selection, range operations, public safety, payload safety, launch approval processes, and the determination of programmatic requirements for launch license applicants.

The Contractor shall perform these efforts for a potential 5-year period (base and (4) one-year options) of performance commencing on the date of award. The estimated value is based on the expected rise in nuclear-enabled missions over the next five years and is not anticipated to exceed $10M. This reflects projected mission cadence and the average cost of

Rev.: 4/2026 developing initial nuclear launch vehicle risk analysis reports, which is approximately $1.4M per mission when accounting for historical procurements, actuals paid, and escalation. With NASA’s Launch Services Program planning for roughly one nuclear mission per year beginning in 2028, five missions would total about $7M.

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 6.103-1 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 rationale supporting the use of 10 U.S.C. 3204(a)(1) is based on ASCA’s specialized expertise and proven capabilities obtained through their extensive execution of ESDs for abundant nuclear missions dating back to 1997, which includes Cassini, Mars Pathfinder, Mars Exploration Rover A and B, Pluto New Horizons, Mars Science Laboratory, Mars2020, Dragonfly and RFM.

Over 30 years, ASCA has developed a comprehensive dataset that includes analytical methods, proprietary tools, and detailed records of NASA flights and anomalies. By incorporating branch-point probabilities into ESDs, ASCA offers a proven approach to evaluating launch-vehicle failure risks. Its extensive global launch history and launch-vehicle database support accurate, mission-specific ESDs. By utilizing ASCA’s expertise services, NASA will reduce schedule risks related to NSPM-20 nuclear approvals and Databook revisions and will be able to accelerate ordering process for nuclear missions.

Through LSP extensive knowledge of nuclear mission requirements and the most recent market research, there were no identified or capable vendors that possess specialized expertise and extensive launch vehicle database to produce the data books. Additionally, a vendor to obtain the specialized expertise would need to reconstruct data similar to ASCA’s proprietary analytical framework that produces mission specific ESDs through globally sourced launch vehicles, such as Russia’s Soyuz, anomalies database dating back to at least 1996. These resources have been refined for more than three decades and are not available through any vendor known by LSP or identified through SAM.gov. Based on LSP’s extensive process expertise, a new vendor would likely need more than a year, and multiple technical review cycles coordinated with NASA, LSP, and the Department of Energy to replicate ASCA’s tools and methodology. This effort could significantly disrupt the schedules of current and near-term nuclear missions, as LSP typically requires complete data books three years before launch to assess risk and inform decision-makers during the launch approval process.

Consequently, NASA will significantly benefit from utilizing ASCA's established proficiency in nuclear launch vehicle risk analysis reports by reducing schedule risk and minimizing potential launch delay costs, in addition to providing a low-cost risk analysis report.

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 August 27, 2026, in accordance with FAR part 5. This posting informed potential sources of NASA’s intent to award this sole-source BPA to ASCA, Inc. The results of this synopsis are summarized in Section 8 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 Blanket Purchase Agreement (BPA), a proposal analysis will be performed. The proposal analysis will ensure that the final agreed-to prices for the BPA are fair and reasonable. The Government will conduct a price analysis to ensure that the not-to-exceed elements of the BPA prices are fair and reasonable, consistent with the FAR 12.203. This analysis will include evaluating the proposed pricing for the study against comparing it against historical prices paid by the Government (historically, $600K-$700K).

The labor categories/hours analysis will be accomplished by reviewing relevant commercial pricing where available and assessing pricing trends over time to determine whether the proposed price reflects current market conditions.

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):

A notice of the requirement was posted on the GPE website on August 27, 2026, in accordance with FAR Part 5 to determine whether capable sources exist. On September 11, 2026, the posting closed with three companies responding DreamCatchers Consulting, LLC, Arctos Technologies Solutions, Inc, and Project Cue, Inc. which were subsequently reviewed by technical.

Market research was conducted through the technical team’s extensive, decades-long knowledge of NASA’s nuclear ESD development and mission specific risk analysis needs to satisfy NSPM-20 nuclear approvals. Based on this expertise, the team determined that DreamCatchers lacked any aerospace experience, relevant past performance, or access to the proprietary datasets and historical flight/anomaly information required for continuity of NASA’s nuclear analysis approach. Their IT focused methods would require redevelopment of prior work and introduce unacceptable schedule and cost impacts. This would require rebuilding prior analysis from the ground up, adopting a new contractor would introduce significant schedule and cost delays, jeopardizing NASA’s ability to obtain timely launch unacceptable.

Similarly, the technical team found that Arctos does not possess the decades of mission history, global launch vehicle database, or Government approved nuclear safety methodologies needed to meet NASA’s timelines; their experience is related to supporting debris assessments for commercial partners that does not satisfy the required nuclear probabilistic risk assessment.

Additionally, as described in Section 10, the Government could not conduct an assessment for Project Cue because it failed to provide the required capabilities statement and instead submitted a proposal, rendering its response non-responsive to the Government’s request.

Following this assessment, as described in Section 10, none of the respondents demonstrated the capacity to satisfy NASA’s nuclear launch approval standards or to provide the required ESD methodology, proprietary data, or schedule needed for NASA Nuclear missions.

Recreating ASCA’s specialized expertise and proprietary analytical framework would require multiple review cycles, increase costs and delays in NASA’s projected nuclear missions.

Therefore, market research confirmed that no viable alternative sources were available, and NASA LSP’s Technical Representative determined that no other responsible source possessed the specialized knowledge and capability required to meet these requirements.

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

None.

10. FAR 6.104-1(a)(10) – A listing of the sources, if any, that expressed an interest in the acquisition in writing:

As mentioned in section 8 above, a notice of NASA’s intent to award this sole source action was posted to the GPE on August 27, 2026 and closed on September 11, 2026. Three companies responded to the notice of intent; two submitted written capability statements and one submitted a non-responsive submittal as described below:

1. DreamCatchers Consulting, LLC and determined more of an IT consulting company.

2. Arctos states that it has empirical experience and comparable vehicle data to establish failure probabilities; where direct experience is limited, gaining expertise comparable to ASCA would significantly impact NASA Nuclear missions.

3. Project Cues, Inc. submitted a proposal instead of the required capabilities statement, The company’s services consist of AI agent development, web infrastructure, and digital automation that are all unrelated to the specialized nuclear launch vehicle risk analysis, proprietary datasets, and ESD methodology required under the ASCA BPA. Furthermore, the submission did not

Government determined that Project Cues was non-responsive as it provided no information on their capabilities to requirement.

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.