A16_JOFOC_Emergency_Lift_Station_Repairs_1.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

Date: 8/21/2026

Reference:

Urgent repairs are required at the upper lift station in Chaco Culture National Historical Park, Nageezi, NM. Immediate action must be taken to rebuild or replace Moyno brand progressing cavity wastewater pumps, along with the replacement of damaged piping, gaskets, fittings, valves, and gauge. Additionally, it is essential to promptly replace or rebuild a Flygt 3102.890 submersible grinder pump. These emergency measures are critical to restore proper wastewater management and prevent further system failure.

Subject: Justification for Other than Full and Open Competition

1. Identification of the Agency and the Contracting Activity: 140P13

2. Nature and/or description of the action being approved:

This action includes the rebuilding or replacement of the Moyno brand progressing cavity wastewater pump to restore its operational capacity. It also authorizes the urgent replacement of all damaged piping, gaskets, fittings, valves, and the gauge to ensure system integrity. In addition, the approved work encompasses the prompt rebuilding or replacement of the Flygt 3102.890 submersible grinder pump. These measures are essential to maintain reliable wastewater management and prevent further system failure.

3. Description of the supplies or services required to meet the agency's needs (including the estimated value):

Rebuilding or replace with new one Moyno brand progressing cavity wastewater pump at the upper lift station including replacing damaged piping, gaskets, fittings, valves, and gauge.

Replacing with new or rebuilding one Flygt 3102.890 submersible grinder pump.

4. Identification of the statutory authority permitting other than full and open competition:

Pursuant to Federal Acquisition Regulation (FAR) 6.302-2, the agency is authorized to limit competition due to urgent and compelling circumstances. This provision allows for other than full and open competition when an unusual and compelling urgency requires the Government to procure supplies or services immediately, and following standard competitive procedures would result in unacceptable delays. The justification for this action is based on the critical need to restore and maintain wastewater management at the upper lift station in Chaco Culture National Historical Park, Nageezi, NM.

Chronologically, the urgency of this requirement is demonstrated as follows:

a. During the week of 07/14/2026, one of two operating Moyno progressing cavity wastewater pumps burned out. The excessive heat generated caused the Schedule 80 piping and fittings to expand, resulting in minor leaks within the wastewater system.

b. Operations continued with the remaining functional pump until 07/24/2026, when the pipeline infrastructure catastrophically failed and exploded during use. Emergency repairs

United States Department of the Interior

NATIONAL PARK SERVICE

CONTRACTING OPERATIONS - CENTRAL

1849 C Street

NW Washington, DC 20240 were made to a portion of the pipe, and the non-functioning pump and lines were isolated so that the second pump could be used.

c. Despite these temporary measures, the system continues to leak in the line currently being used to move waste, indicating a limited window of time before the entire system fails.

d. Simultaneously, the lower lift station pump ceased to operate, leaving only one pump to handle both systems, a critical vulnerability that substantially increases the risk of total system failure.

e. If the lift station pumps are not replaced and the plumbing for the upper lift station is not addressed immediately, there is a significant risk of catastrophic failure, which could lead to a severe environmental disaster involving the spill of human waste and effluent into culturally sensitive and heavily utilized areas of Chaco Culture National Historical Park.

f. These circumstances create an urgent and compelling need for immediate repairs and replacements to prevent further system failure and mitigate environmental and cultural impacts.

Therefore, immediate action is required under FAR 6.302-2 to limit competition and expedite the procurement process, ensuring the continued safe management of wastewater and preventing significant harm to the park and its visitors. These urgent measures also serve to uphold the mission of Chaco Culture National Historical Park and the National Park Service by protecting natural resources, preserving cultural heritage, and ensuring the health and safety of all who visit and work at the park.

5. Demonstration that the proposed contractor's unique qualifications or the nature of the acquisition requires using the authority cited:

Hennesy Mechanical Sales, LLC, now acquired by DXP Enterprises, demonstrates unique qualifications essential to the successful and timely completion of this emergency pump rebuild requirement. As evidenced in their technical proposal and detailed repair scope for the Moyno PC Pump assembly and associated components, Hennesy possesses direct, brand‑specific expertise with the exact pump model installed at the Chaco Canyon WWTP, including specialized knowledge of rotor/stator compatibility, proprietary gasket assemblies, and OEM part integration.

Their technicians are already familiar with the configuration, failure modes, and teardown requirements of the installed equipment, as reflected in their comprehensive parts listing, specialized tooling needs, and multi‑day service plan within the quote. Additionally, DXP Enterprises’ acquisition of Hennesy Mechanical Sales expands their technical bench strength, supply‑chain reach, and access to OEM parts, providing the Government with a single, fully capable service provider that can deliver both emergency field labor and manufacturer‑authorized components without delay. This combined capability, along with their proven history of supporting pump repairs at the same operational site, establishes a unique familiarity and specialized competence that is not reasonably available from other sources, fully justifying their selection for sole‑source award.

6. Description of efforts made to ensure that offers are solicited from as many potential sources as possible, including whether a notice was or will be publicized as required by FAR Part 5 and, if not, which exception under Part 5 applies:

Because the Government’s need for emergency pump rebuild services is of such an unusual and compelling urgency that failure to act immediately would result in serious harm to mission-critical operations, the contracting officer determined that providing the advance notice required under FAR 5.201 would cause unacceptable delay. In accordance with FAR 5.202(a)(2), the agency is exempt from publicizing this action on the Governmentwide Point of Entry, as the time required for synopsis and response would jeopardize the Government’s ability to restore essential services, prevent further system degradation, and mitigate safety and environmental risk. The circumstances of this requirement fully support use of the statutory authority at FAR 6.302‑2, and the corresponding synopsis exception at FAR 5.202(a)(2), because immediate award is necessary to meet urgent operational needs and no other procurement approach can meet the required response timeframe.

7. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable:

The anticipated cost to the Government is determined to be fair and reasonable based on a thorough evaluation of all available pricing information and applicable regulatory guidance. The Contracting Officer independently reviewed the contractor’s proposal against the Government’s requirements, validated the cost elements through comparison with the Independent Government Estimate (IGE), and confirmed alignment with recent, similar procurements of comparable scope and complexity. In accordance with the price analysis techniques described in FAR 13.106‑3(a), including comparison to historical pricing, evaluation of market research, and assessment of cost realism, the proposed price is consistent with prevailing market conditions and reflects a reasonable allocation of labor, materials, and associated expenses. No inconsistencies, unbalanced pricing, or indicators of excessive cost were identified. Accordingly, the Contracting Officer concludes that the anticipated cost represents a fair and reasonable expenditure of Government funds.

8. Market research conducted (see FAR Part 10) and the results or a statement of the reason market research was not conducted:

Market research for this requirement was conducted in accordance with FAR Part 10 and included a comprehensive review of available sources, pricing, and technical capabilities for emergency pump rebuild and replacement services. Multiple vendors were contacted and provided detailed quotes for both repair and replacement of the required pump assemblies, including James Cooke and Hobson Inc (ABQ) and Hennesy Mechanical Sales. The scope of market research encompassed evaluation of parts, labor, lead times, and technical specifications for both Flygt and Moyno pump models, as documented in the attached quotes and supporting materials. Pricing was compared across vendors and against the Independent Government Estimate (IGE), confirming that the proposed costs are consistent with prevailing market rates for similar emergency repairs and replacements. Lead times, warranty terms, and service conditions were also assessed to ensure responsiveness to the urgent operational need. No other vendors were identified that could meet the required delivery, technical specifications, and immediate response timeframe. The results of this market research demonstrate that the selected contractor Hennesy Mechanical Sales, LLC offers the most responsive and technically capable solution at a fair and reasonable price, fully supporting the urgency and sole source determination for this action.

9. Any other facts supporting using other than full and open competition:

None.

CERTIFICATIONS AND APPROVALS

Technical Certification:

I certify that any supporting data that is the responsibility of technical or requirements personnel which form a basis for the justification has been certified as complete and accurate:

Signature:

Contracting Officer Certification:

I certify that the justification is accurate and complete to the best of my knowledge and belief:

Signature:

Over $50,000

Warranted Individual 1 Level Above Contracting Officer

Signature:

I certify that any supporting data that is the responsibility of technical or requirements personnel which form a basis for the justification has been certified as complete and accurate: