Tab 108 Justification for Other than Full and Open Competition (JOFOC)_Redacted.pdf

Rev.:4/2026

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

NASA IT Procurement Office (ITPO)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For BlueHalo Robo-Met.3D Automated Serial Sectioning System

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) IT Procurement Office (ITPO). The procuring agency is NASA, and the contracting activity is ITPO.

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

This justification provides the rationale for contracting by other than full and open competition to award a sole-source contract with Blue Halo, LLC.

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 Kennedy Space Center (KSC) requires the purchase of Blue Halo Robo-Met.3D Automated Serial Sectioning System from BlueHalo, LLC which is needed for Materials Analysis Laboratory located in the O&C Building, Room 2211, to provide advanced three-dimensional (3D) microstructural characterization capabilities in support of NASA mission and materials evaluation requirements. The total estimated price of the proposed order is and the estimated lead-time for delivery is 26 Weeks ARO.

The Robo-Met.3D system enables automated serial sectioning and reconstruction of material microstructures into quantitative 3D datasets. This capability allows laboratory personnel to analyze features such as porosity, inclusions, grain structures, cracks, and other microstructural characteristics in three dimensions rather than relying solely on traditional two-dimensional metallographic techniques. The system will significantly improve analytical efficiency, reduce labor-intensive manual processes, and provide more comprehensive and accurate characterization results.

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 for acquisitions using the procedures in FAR 12.102 is 41 U.S.C. 1901.

Rev.: 4/2026

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) is BlueHalo, LLC is the sole source provider for this requirement as described below.

NASA Kennedy Space Center conducted market research through internet searches, review of published technical literature, and consultation with other organizations currently utilizing Robo-Met systems. Alternative technologies identified included focused ion beam-scanning electron microscopy (FIB-SEM) serial sectioning and X-ray computed tomography (XCT).

The Agency's minimum requirements include automated metallographic serial sectioning, integrated optical microscopy, large-volume three-dimensional characterization, automated image acquisition, and turnkey 3D reconstruction within a single commercially available system. Market research determined that while FIB-SEM and XCT systems provide certain three-dimensional characterization capabilities, they do not provide the required combination of capabilities necessary for routine materials characterization and failure analysis. In addition, these alternative technologies would require significant customization, integration of multiple systems, or additional equipment purchases to meet NASA's requirements.

Based on the market research performed, BlueHalo's Robo-Met.3D Automated Serial Sectioning System was determined to be the only commercially available product that possesses the specific features essential to NASA's requirements. No other manufacturer's product was identified that meets, or could be reasonably modified to meet, the Agency's needs without substantial additional cost, development effort, or technical risk. The system's maturity and broad application within the materials science community are further demonstrated through an extensive body of published research documented in the Robo-Met publication database maintained by BlueHalo/UES. (https://www.ues.com/rmresources)

The Government's minimum requirement is the ability to perform automated 3D microstructural analysis through serial sectioning and reconstruction. At the time of this acquisition, the Robo-Met.3D system is the only commercially available product that satisfies this requirement without the need for significant custom development, integration of multiple vendor components, or creation of a laboratory-built solution. Alternative approaches would require substantial engineering effort, increased technical risk, additional procurement actions, and extended implementation schedules.

Failure to acquire this capability would limit the laboratory's ability to conduct advanced 3D materials characterization and would require continued reliance on more time-consuming, labor-intensive, and less comprehensive analytical methods. Acquisition of the Robo-Met.3D system will provide a new analytical capability that directly supports NASA materials evaluation, failure analysis, research, and engineering activities while improving productivity and quality of results.

BlueHalo, LLC is the only known source capable of providing the required commercially available automated serial sectioning system with integrated 3D metallographic reconstruction and analysis capability. Therefore, a limited-sources acquisition is justified.

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 July 16, 2026, in accordance with FAR Subpart 5.1. This posting informed potential sources of NASA’s intent to award this sole-source contract to Blue Halo, 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. In accordance with FAR 13.106-3, a statement of price reasonableness will be documented in the contract file citing historical prices and any other reasonable basis.

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):

Market research was conducted to identify commercially available systems capable of meeting NASA Kennedy Space Center's technical requirements for automated serial sectioning, failure analysis, and materials characterization. Research included multiple internet searches, a review of commercially available technologies, and coordination with other NASA Centers currently using comparable systems, including those utilizing the RoboMet.3D platform.

The market research identified several alternative technologies, including Tescan's FIB-SEM serial sectioning systems and North Star Imaging's X-ray computed tomography (CT) systems. While these technologies provide specialized imaging and characterization capabilities, none offer the integrated functionality required for routine laboratory operations.

Specifically, the identified alternatives do not provide the combination of large-volume automated metallographic serial sectioning, integrated optical microscopy, automated image acquisition, turnkey 3D reconstruction, and workflow automation necessary to satisfy the Government's technical requirements without significant customization, additional equipment acquisitions, or extensive software integration.

Based on the results of the market research, BlueHalo's RoboMet.3D was determined to be the only commercially available system that satisfies all of the Government's minimum technical requirements as a complete, turnkey solution. Additionally, BlueHalo, LLC confirmed via email dated May 11, 2026, that it is the sole manufacturer and seller of the RoboMet.3D Serial Sectioning System and that no authorized resellers or distributors exist.

Accordingly, no other known commercial source is capable of providing the required system.

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 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). The intent to sole source was posted on SAM.gov on July 16, 2026 and closed on July 24, 2026. No responses were received in regard to this intent to sole source.

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.