A02 - JUSTIFICATION AND APPROVAL - Walnut Ridge Lift Stations Final_Redacted.pdf

MVR-26-021

Justification for Other than Full and Open Competition U.S. Army Corps of Engineers, Rock Island District

Revolutionary FAR Overhaul (RFO) 6.103-2(b)

1. Requiring and Contracting Activity:

U.S. Army Corps of Engineers, Rock Island District, Rock Island, Illinois (CEMVR-CT).

2. Description of Action:

This procurement will result in a firm fixed price purchase order awarded on a sole source basis to Electric Pump LLC for the urgent supply and installation of two (2) replacement sewer lift stations at the Walnut Ridge Recreation Area, Saylorville Lake, Johnston, Iowa.

3. Description of Action and Supplies/Services:

The Contractor shall provide all equipment, labor, and materials necessary to remove the existing failed infrastructure and supply and install two (2) new sewer lift stations (North and South). The equipment includes Barnes 3XSHMPA3074 (3 HP) submersible pumps, or an approved equal, custom simplex control panels, internal piping, check valves, and guide rail systems. The Contractor must also perform site preparation, electrical integration, and system testing.

Estimated Value:

O&M funding will be utilized for this contract action.

4. Authority Cited:

Title 10 U.S.C. 3204(a)(2); RFO 6.103-2(b),1 unusual and compelling urgency.

5. Rationale or Circumstances for Limiting Competition:

1 This J&A is subject to the following class deviations: 2026-O0017, dated 18 Dec. 2025; and 2026-O028, dated 18 Dec. 2025. These deviations make the draft Revolutionary FAR Overhaul (RFO FAR) applicable to this J&A. The RFO FAR citations within this document are current as of 24 June 2026.

The statutory authority permitting other than full and open competition due to unusual and compelling urgency is 10 U.S.C. section 3204(a)(2), as implemented by RFO Part 6, section 6.103-2.

The current sewer lift stations serving the Walnut Ridge Recreation Area have failed.

The recreation area relies on a wastewater system utilizing mound system cells, which currently have limited holding capacity. Because the lift stations are inoperable, it is urgent to restore the ability to pump effluent to the leach fields so the sewage can be properly treated before the mound cells reach their maximum capacity.

The Walnut Ridge Recreation Area is an extremely high traffic, heavily utilized public facility. It features multiple waterborne restroom facilities, three large group shelters, a volunteer campsite, and an 18-hole championship-level disc golf course that hosts multiple large-scale tournaments annually. If the mound cells reach capacity due to the inability to pump to the leach fields, it could result in the immediate closure of these public restrooms and facilities, or necessitate additional, costly sewer pumping service contracts to continuously haul the wastewater offsite. Shutting down these facilities would disrupt scheduled events and significantly impact public sanitation, while relying on emergency pumping services would place an undue financial burden on the Government.

Beyond the severe administrative and financial impacts, an unaddressed failure of these lift stations presents an immediate and critical threat to public health and the surrounding environment. Because the recreation area utilizes a restricted-capacity mound wastewater system, a capacity breach will inevitably lead to localized surface ponding of untreated effluent or backup failures. This creates an exposure pathway for highly infectious waterborne pathogens (such as E. coli and fecal coliforms) to the high-traffic public areas. Furthermore, given Walnut Ridge's proximity to Saylorville Lake, any uncontrolled surface runoff of untreated sewage poses an imminent risk of contaminating a protected federal reservoir and public water supply, triggering environmental compliance violations, severe ecological degradation of local wildlife habitats, and mandatory long-term closure of the entire recreation area by public health authorities.

Due to the emergent nature of this failure, there is a strict time restriction to restore operational capabilities. Competing this requirement through standard solicitation procedures would introduce delays, increasing the likelihood of system capacity being exceeded and forcing park closures or costly pumping alternatives. Furthermore, Electric Pump has been conducting repairs on the existing pumps and possesses site-specific experience and knowledge of the unique characteristics of this system.

Because of this established operational history, they are uniquely positioned to immediately mobilize and execute the replacement. Engaging another vendor at this stage would introduce a significant learning curve, requiring new site assessments, engineering submittals, and lead times that the Government cannot accommodate given the limited remaining capacity of the current holding cells.

In addition, there are only two vendors in this general vicinity who perform this type of work, and one of the companies is not a viable candidate, as discussed below.

6. Alternatives, and Impact if Not Approved:

Based upon market research, as noted below, Electric Pump is the only viable alternative for this action. given the strict time constraints and the need to prevent the mound system cells from reaching capacity, which would lead to the closure of the facilities and emergency services required of the Government, as noted above.

7. Efforts to Obtain Competition:

Due to the unusual and compelling urgency of the situation and the immediate need to restore proper wastewater treatment capabilities, full and open competition was not feasible. As discussed above, all viable “potential sources” from whom it would be practicable to solicit offers have been solicited, in compliance with RFO 6.103-1(c). In accordance with the exemption at RFO 5.101(b)(2), “using other than full and open competition” (see 6.103), no presolicitation notice of intent to sole source will be published on SAM.gov because neither of the exceptions to this exemption (6.103-1 (only one responsible source) nor 6.103-6 (national security)) applies.

8. Actions to Increase Competition:

This is an urgent replacement due to unexpected equipment failure. For future requirements, USACE will proactively monitor the lifecycle of lift station infrastructure and plan replacements well in advance of failure to ensure full and open competition can be achieved.

9. Subcontracting Competition: NA

10. Market Research:

In accordance with RFO 10.001, market research for this requirement was scaled and limited to a review of historical procurement data, local technical surveillance, and the technical team's direct working experience with regional wastewater service providers.

Due to the unusual and compelling urgency of the impending wastewater system failure, conducting a protracted formal market survey—such as issuing a Sources Sought Notice or a Request for Information (RFI)—was determined to be impractical. Doing so would introduce critical delays, directly increasing the risk of a catastrophic system overflow. Consequently, the Government relied on the technical agency's robust, ongoing knowledge of the local industrial base and direct past experience to assess vendor capabilities in the immediate geographic vicinity.

Additionally, the required sewer lift stations, components, and installation services are commercial products and services as defined in RFO 2.101, as they are of a type customarily sold to the general public for municipal and commercial wastewater management. This acquisition will utilize commercial procedures under RFO Part 12.

Electric Pump is proposed as the sole source due to their history of conducting repairs on the existing lift stations, giving them unmatched, unique knowledge of the current system.

Given the strict time constraints and the need to prevent the mound system cells from reaching capacity, the Government cannot accept the risk of delivery delays or poor communication.

To properly operate a major high-traffic recreation area like Walnut Ridge, we require a local vendor capable of providing reliable, 24/7/365 emergency service and rapid response. Electric Pump LLC has become our established local partner and provides exactly this level of reliability. They maintain a fleet of fully equipped service vehicles and over 50 factory-trained technicians right here in the area. They already have

Contracting Officer Certification and Approval:

I certify that this justification is accurate and complete to the best of my knowledge and belief. Based on the justification above, I hereby approve the procurement of the Walnut Ridge Recreation Area Lift Station replacements on an other than full and open competition basis. This approval is subject to the availability of funds, and provided that the supplies and/or services herein described have otherwise been authorized for this acquisition.

Ryan Larrison Contracting Officer USACE Rock Island District