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JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION in accordance with FAR Subpart 6.302-1 This document is being prepared pursuant to the content requirements prescribed in Federal Acquisition Reg... JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION in accordance with FAR Subpart 6.302-1 This document is being prepared pursuant to the content requirements prescribed in Federal Acquisition Regulation (FAR) Subpart FAR 6.303-2(b)1. FAR 6.303-2(b)(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": Agency: Environmental Protection Agency Contracting Activity: Office of Mission Support (OMS) Office of Acquisition Solutions (OAS) Headquarters Acquisition Division (HQAD) Program Office: Office of Land and Emergency Management (OLEM) Office of Emergency Management (OEM) Program POC: Duane Newell, OLEM/OEM Project Identification: 68HERH25C0005: Portable High Throughput Integrated Laboratory Identification Systems (PHILIS) Platform Modernization, Change Order Proposed Source(s): MRIGLOBAL (UEI: HKQHNFKNKL15) 2. FAR 6.303-2(b)(2), Nature and/or description of the action being approved: The purpose of this justification is to increase the capacity (i.e., ceiling) of EPA’s contract, 68HERH25C0005, with MRIGLOBAL by $530,000.00. This increase is necessary to account for unexpected subcontractor Craftsman’s design iterations, requirement expansions, and raw material increases that have caused variances outside the current ceiling price. The aforementioned changes do not impact the scope of the contract, but do require a five (5) month extension to the period of performance (which currently expires January 21, 2026), and represent an approximately a 4% increase to the current $13,078,279.00 ceiling of the contract. 3. FAR 6.303-2(b)(3), A description of the supplies or services required to meet the agency’s needs (including the estimated value): The United States Environmental Protection Agency’s (EPA) Office of Land and Emergency Management (OLEM), Office of Emergency Management (OEM), Chemical, Biological, Radiological, and Nuclear Consequence Management Advisory Team (CMAT) is one of EPA’s four (4) Special Teams, which were designed to provide general and specialized capabilities during emergency responses, time critical responses, and non- time critical responses. CMAT’s mission is to prepare for and support the removal and remedial response community 24/7/365 during all hazards to protect human health and the environment. The PHILIS laboratory systems were designed to detect Chemical Warfare Agents (CWAs) and Toxic Industrial Chemicals (TICs). Multimedia Volatile Organic compound (VOC) and Semi-volatile organic compound (SVOC) analysis is performed in the laboratories as well as other analyses as needed. The PHILIS Program provides on-site mobile and base of operations laboratory capabilities to respond to CWA and TIC releases, as well as any supplementary locations that are deemed fundamental to accomplishing EPA’s mission. This capability is unique and not replicated by any other government program, federal or state, and is critical to restoring contaminated areas for safe public use after a chemical release. The current contract, 68HERH25C0005, replaces the mobile operational laboratory platforms and optimizes the operations of the PHILIS units located in Edison, New Jersey and Castle Rock, Colorado in accordance with the attached Technical Specifications. Subcontractor Craftsman’s design iterations, unexpected requirement expansions, and raw material costs increases (including tariffs) have caused unexpected but necessary variances totaling a net amount of $530,000.00. The variances include offsets of increased costs for certain changes with decreases in other costs for design elements that were no longer determined to be needed. Those variances include: upgrading to the HVAC system on Prep-Labs due to the number of hoods; upgrades to variable speed hood control system on Prep-labs to balance HVAC system; security enclosures around HVAC and generator systems; optimization of the instrument heat management system; increased costs of labor and good/materials; and higher tariff costs. Through the program’s review and final approval of the designs, the Government found that the changes to the designs from the original concept and assumptions were necessary to ensure highly functional, safe, and compliant designs. The design and optimization required under this contract cannot be completed without incorporating these necessary changes. If implemented, the variances would warrant a net increase of $530,000.00 in the $10,468,223.00 ceiling price for Other Direct Costs (ODCs). 4. FAR 6.303-2(b)(4), An identification of the statutory authority permitting other than full and open competition. This Justification for Other Than Full and Open Competition (JOFOC) is being issued pursuant to the authority granted by 41 U.S.C.253(c) (1): Only one responsible source and no other supplies or services will satisfy agency requirements as implemented by FAR 6.302-1. 5. FAR 6.303-2(b)(5), A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited. The nature of the circumstances required to support the rationale for using the authority as cited under the previous section, “Only one responsible source and no other supplies or services will satisfy agency requirements as implemented by paragraph 6.302-1 of the Federal Acquisition Regulations (FAR)”, is detailed below. The Contracting Officer has determined that the only way to ensure the mission critical design and optimization services performed under 68HERH25C0005 can be completed is to incorporatethe changes into the current contract with MRIGLOBAL and increase the ceiling by $530,000.00 for those changes. At this time, nine (9) months into performance, design and fabrication are well underway, with 90% of the final design of the labs being completed. Because of the specific knowledge and performance required for the execution of the requirements of the contract, the learning curve would be substantial and impractical for a new contractor with 90% of the design already being completed. Therefore, there are presently no other contractors other than MRIGLOBAL capable of completing the necessary changes to their own design without causing detrimental delays to the program’s ability to ready the labs for restoring contaminated areas for safe public use after a chemical release. A lapse in these critical services would result in the Agency being unable to meet its mission and result in endangerment to the public’s health, welfare and environment. Bringing in a new contractor at this point, when the design is nearly completed, would require a full review and evaluation of a new firm’s capabilities to ensure the same level of design and optimization support. Therefore, at this time, increasing the ceiling of 68HERH25C0005 to incorporate the required design changes and accommodate the increase in the cost of materials and tariffs to ensure the labs are ready to respond to CWA and TIC releases is the only viable option. Any other approach would likely result in duplicative costs on the Government and contractors part that would not be recovered through any savings that might be attained through competition. Due to this requirement not having duplicate services under other contract vehicles, there is currently only one source to obtain the specific knowledge and experience necessary to ensure no adverse impact to the completing the work currently provided under this contract. 6. FAR 6.303-2(b)(6), A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by subpart 5.2 and, if not, which exception under 5.202 applies. Since this justification is for an increase to an existing EPA contract (68HERH25C0005), offers will not be solicited from any additional sources beyond MRIGLOBAL. As required by FAR 5.201(b) and in accordance with FAR 5.203(a), a notice of the proposed contract actions requested herein was posted on October 29, 2025 at the Government Point of Entry (GPE) (https://www.SAM.gov), and closed November 5, 2025 at 4:30 PM Eastern Standard Time (EST). A copy of the notice is attached hereto and available at: https://sam.gov/opp/0bfeacc5eec34a9aa8f3ba778e621000/view. EPA did not receive any responses to the notice. In accordance with FAR 6.305, within 14 days after issuing the modification to increase the ceiling of 68HERH25C0005, this justification will be published (i.e., made publicly available) in accordance with FAR 5.301. The justification will be posted at the Government Point of Entry (GPE) (https://www.Sam.gov), which will provide access to the justification by linking to the GPE, for a minimum of 30 days. Any responses received to the notice and/or justification will be recorded and retained as a listing of interested and/or prospective sources to be included in EPA’s market research for future OLEM portable laboratory identification systems and/or modernizations to existing systems 7. FAR 6.303-2(b)(7), A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable: The existing support currently being performed by MRIGLOBAL under 68HERH25C0005 was competitively awarded in accordance with the policies and procedures governing competitive acquisitions under FAR Part 15, Contracting by Negotiation, as supplemented by FAR Part 12, Acquisition of Commercial Products and Commercial Services on January 22, 2025. At the time of contract award, the labor and other direct costs, and total anticipated cost to the Government were determined to be fair and reasonable. The Contracting Officer, in collaboration with the cognizant technical personnel, will ensure that the magnitude of effort and proposed cost for the changes to be incorporated via the proposed contract action will be fair, reasonable, and consistent with commercially available pricing for the changes to be incorporated herein. 8. FAR 6.303-2(b)(8), A description of the market research conducted (see part 10) and the results or a statement of the reason market research was not conducted: No market research was conducted for this proposed action because this action is intended to be issued as a change order against 68HERH25C0005 as permitted by and in accordance with 9. FAR 6.303-2(b)(9), Any other facts supporting the justification: A change order was issued by the Contracting Officer via email on September 30, 2025 in accordance with FAR 52.243-1, Changes, of the contract to incorporate some of the changes indicated herein, valued at $258,836.00. This justification is intended to increase the ceiling of the contract by $530,000.00 to restore the value of the changes contained in the change order, and additional $271,164.00 in ceiling to complete the remaining changes that still need to be completed as described in Section 3 herein. 10. FAR 6.303-2(b)(10), A listing of the sources, if any, that expressed, in writing, an interest in the acquisition: No responses were received in response to the notice of the proposed contract actions. 11. FAR 6.303-2(b)(11), A statement of the 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: No barriers to future competition exist, as this contract was awarded resulting from an unrestricted, full and open competition, and any future similar requirement is also intended to be procured utilizing unrestricted competitive procedures. Since this justification is requesting a sole-source increase to the existing contract, 68HERH25C0005, a proposal will not be solicited from any additional sources beyond MRIGLOBAL to incorporate the changes and increased cost of performance as a result of those changes.