A07 LOX Urgent and Compelling Sole Source Memo - Signed.pdf

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Liquid Oxygen Delivery
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89503625PSW000264
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This document is a Memorandum to the Record justifying a sole-source acquisition for liquid oxygen (LOX) delivery by the Southwestern Power Administration (SWPA). The urgent procurement is for bulk liquid oxygen deliveries to support dissolved oxygen injection operations at the Table Rock Dam Powerhouse in Branson, MO, with specific technical requirements including 99.5% oxygen content, less than 0.5% inert gases, and a dew point of minus 80°F or lower. The estimated contract value is $250,000.00, with deliveries planned from August through December 2025, to be fulfilled by RAS Enterprises, LLC.

The sole-source justification stems from an unexpected contract failure: SWPA initially awarded a small business contract on June 26, 2025, but the awardee informed them on July 24, 2025 that they could not perform. With the critical LOX delivery period beginning in August, SWPA determined that recompeting the requirement would cause a lapse in deliveries. The LOX is mission-critical for maintaining power generation and environmental compliance, as it helps prevent fish kills by elevating dissolved oxygen levels during low-oxygen periods, and is 3-7 times more cost-effective than purchasing supplemental power.

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III. THE DETERMINATION FOR USE OF OTHER THAN FULL AND OPEN

COMPETITION IS BASED ON THE FOLLOWING:

UNUSUAL AND COMPELLING URGENCY -

The need for LOX is considered mission-critical to maintain generation operations and environmental compliance at Table Rock Dam during periods oflow dissolved oxygen (D.O.), which historically begin in August each year. When D.O. levels fall below 4.0 parts per million (ppm), the USACE imposes Recommended Maximum Generation (RMG) restrictions to prevent fish kills. These RMGs significantly reduce power generation capacity.

The injection of LOX mitigates these restrictions by elevating D.O. levels in the tailrace, enabling SWPA to operate units at or near nameplate capacity. A critical requirement for meeting the Southwestern Marketing Plan and customer demands.

LOX injection is also 3 to 7 times more cost-effective than supplementing power shortfalls through purchase power. Failure to obtain LOX in time would result in:

• Increased energy costs

• Reduced operational efficiency

• Elevated environmental risk (e.g., fish kills and potential regulatory violations)

• Inability to meet customer energy needs

IV. CIRCUMSTANCES SUPPORTING URGENCY:

On June 26, 2025, SWP A awarded a contract for liquid oxygen (LOX) deliveries through 100% small business set-aside. However, on July 24, 2025, the awardee informed SWP A that they were unable to perform under the awarded contract. This unexpected development occurred just days before the critical LOX delivery period scheduled to begin in August 2025. Given the limited time, recompeting the requirement, including conducting a site visit and evaluating new proposals, cannot be accomplished without causing a lapse in deliveries. RAS Enterprises, LLC, a proven supplier with a successful history of delivering LOX to this facility, is currently the only known vendor capable of meeting the technical and delivery requirements on an immediate basis.

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JIMMY

WHEELER

Digitally signed by JIMMY

WHEELER

Date: 2025.07.25 15:44:46 -05'00'

2025-07-31T15:14:53-0500
BROOKE BUTCHER

File details come from the government source that posted it. Updated .