Justification Authorization Sole Source, PFAS Remedial Investigation at Iowa Army Ammunition Plant (IAAP)

The Government intends to sole source this Out of Scope Modification, (P0007) on Task Order W912QR21F0421, pursuant to FAR 6.302-1(a)(2)(iii)(B): "For DoD, NASA, and the Coast Guard, services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in unacceptable delays in fulfilling the agency's requirements." PFAS Methodology requirements are listed below:

This policy identifies requirements for sampling of Per- and Polyfluoroalkyl Substances (PF AS) in environmental matrices other than drinking water.

This memorandum supersedes and cancels the Assistant Secretary of Defense for Sustainment (ASD(S)) memorandum, Update for Establishing a Consistent Methodology for the Analysis of Per- and Polyfluoroalkyl Substances in Media Other than Drinking Water, December 7, 2021. For definitive analysis of matrices other than drinking water, the DoD Components will use Draft Method 1633 Analysis of Per- and Polyfluoroalkyl Substances (PF AS) in Aqueous, Solid, Biosolids, and Tissue Samples by LC-MS/MS.

The U.S. Environmental Protection Agency (EPA), in partnership with DoD's Strategic Environmental Research and Development Program, has published Draft Method 1633, a single-laboratory validated method to test for 40 PF AS in media, such as wastewater, surface water, groundwater, soil, biosolids, sediment, landfill leachate, and fish tissue. Other methods for analysis may be considered for screening samples to determine the presence or magnitude of PF AS concentration, but not to confirm absence.

The use of alternative screening methods for a location must be approved by a DoD project representative (e.g., chemist). Methods other than Draft Method 1633 shall not be used to analyze samples for regulatory compliance, risk assessment, or comparison to a project screening or action level. The DoD Environmental Data Quality Workgroup (EDQW) has determined that Draft Method 1633 meets the precision, accuracy, and limits of quantitation needed to support decisionmaking.

Contracts and task orders awarded after the signature date of this memorandum will require the use of Draft Method 163 3 for the definitive analysis of PF AS in matrices other than drinking water using a DoD Environmental Laboratory Accreditation program (ELAP) accredited laboratory certified for the method/matrix/analyte.