Limited Source Justification_Redacted.pdf

Central Federal Lands Highway Division

LIMITED-SOURCES JUSTIFICATION

AUTHORITY: FAR 8.405-6 and 40 U.S.C. 501

1. Identification of the agency and contracting activity, and specific identification of the document as "Limited-Sources Justification."

DEPARTMENT OF TRANSPORTATION

Federal Highway Administration (FHWA), Central Federal Lands Highway Division (CFLHD) Lakewood, Colorado.

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

This action is a sole-source, mixed Firm-Fixed-Price Task Order to be awarded to Stantec Consulting Services Inc. under GSA Multiple Award Schedule (MAS) Contract Number 47QRAA19D000Q. This task order is designated for the 2026 Materials Laboratory Spill Cleanup Project (MLSCP) Semiannual Sampling Events and Environmental Consulting Services located at the Denver Federal Center (DFC) in Lakewood, Colorado. These critical services support FHWA- CFLHD's ongoing environmental compliance obligations under Colorado Department of Public Health and the Environment (CDPHE) Compliance Order No. 91-01-24-03a (Record Manager Code: M&E 3.2).

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value).

To satisfy mandatory environmental remediation requirements, the government requires highly specialized environmental consulting, operations, maintenance, and long-term groundwater monitoring services at the Denver Federal Center. Stantec must perform required services to fully satisfy the government's operational and regulatory mandates.

Task 1: The contractor is required to perform comprehensive project planning, scheduling, financial tracking, and technical coordination with FHWA and the CDPHE. Responsibilities include managing selected contracted laboratories/vendors (such as Eurofins environmental analytical laboratory), conducting safety audits, updating the Site-Specific Health and Safety Plan (HASP) to reflect site conditions, and executing two site audits during the sampling events.

Task 2: The contractor must implement the first 2026 semiannual groundwater and surface water monitoring and sampling event (typically in the spring). This requirement consists of mobilizing specialized personnel and sampling equipment to the site to sample 106 unique locations, including monitoring wells, active pumping wells, surface water points, and groundwater treatment system influent locations. All sampling must be conducted using hand-bailing purge methods or approved protocols in strict accordance with the CDPHE-approved Quality Assurance Project Plan (QAPP) dated July 29, 2022. The contractor must collect up to 162 total primary and field quality control samples (trip blanks, duplicates, and matrix spike and matrix spike duplicate (MS/MSD) samples), record geochemical field parameters (DO, ORP, temperature, EC, and pH), and coordinate analytical laboratory testing for Volatile Organic Compounds (VOCs) and 1,4-dioxane.

Task 3: The contractor must execute the second 2026 semiannual groundwater and surface water monitoring and sampling event (typically in the summer). The contractor is required to perform the identical scope of work as described in the first event, including field mobilization, quality control sampling, laboratory coordination, and laboratory analysis for the same 106 unique sampling locations.

Task 4: The contractor must perform data validation and quality assurance/quality control (QA/QC) verification for all laboratory analytical data generated. The contractor is required to screen analytical results against applicable site regulatory criteria, upload electronic data deliverables (EDDs) directly to the FHWA , and plot geospatial coordinates for new monitoring locations within the program's ArcGIS Geodatabase.

Task 5: The contractor must compile 2026 analytical data and prepare the 2026 Performance Evaluation Report (PER) to evaluate the effectiveness of the Building 52A groundwater treatment system in meeting CDPHE requirements. The contractor is required to perform groundwater potentiometric analysis, extraction well flow rate calculations, and summarize monthly National Pollutant Discharge Elimination System (NPDES) permit sampling results, submitting both Draft and Final reports to FHWA and CDPHE for review.

Task 6: The contractor must prepare the 2026 Long-Term Monitoring Report (LTMR) to summarize and evaluate groundwater and surface water environmental data collected during both semiannual events. The report must evaluate contaminant plume stability and site remediation trends and be submitted as Draft and Final deliverables to FHWA and CDPHE.

Task 7: The contractor must perform non-routine environmental field and office support services on an as-needed, time-and-materials basis when authorized in writing by FHWA. These activities include responding to unforeseen project needs, regulatory modifications directed by CDPHE, additional sampling, or emergency troubleshooting of an inoperative groundwater treatment system.

The total estimated value of these required services is

4. Identification of the justification rationale and a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

The authority permitting restricted consideration under GSA Federal Supply Schedules is FAR 8.405-6(a)(1)(i)(B): "Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized."

Stantec possesses highly specialized technical capabilities and proprietary control over historical project data, making them the only source capable of satisfying these requirements without causing severe, unacceptable compliance delays and significant duplication of costs:

Stantec has served as the sole environmental operations and maintenance consultant for the DFC Materials Laboratory Spill site since its inception. The Source Area Corrective Measure (SACM) remediation system has been operational since 2001 and consists of delicate pneumatic extraction wells and highly fragile, aging, below-grade double-walled transfer piping. Stantec's field staff possess a thorough, hands-on mechanical understanding of this sensitive infrastructure, enabling them to troubleshoot and operate the system safely. A new contractor would require months of onboarding, exposing the government to substantial compliance risk and accidental damage to fragile piping.

Stantec maintains exclusive, proprietary custody of the historical FHWA

. These integrated databases hold multi-decade historical compliance, geological, and geographical datasets essential for the mandatory trend modeling and potentiometric analyses required in annual regulatory reports. Transitioning this complex data repository to a new vendor would involve duplicate software development fees, database alignment fees, and severe technical risks of data corruption or loss, directly impacting regulatory submissions.

To support the 2026 scope of work, Stantec coordinated with the CDPHE to finalize the required environmental monitoring network. Due to stringent regulatory mandates, the required sampling points have increased by 51% compared to the 2025 program. The resulting network comprises 106 unique sampling locations, including difficult-to-find wells distributed across federal property and sensitive local locations, such as the Jefferson County School District property to the east. Stantec's proven field familiarity ensures immediate, safe access and precise monitoring without disrupting active educational areas or generating community concern.

Stantec has established direct, collaborative working relationships with both FHWA-CFLHD technical leads and Colorado state regulators (CDPHE). Their thorough knowledge of the compliance history, specific technical parameters, and State reporting formats is indispensable to ensuring FHWA remains in full compliance with the state's Compliance Order and federal NPDES discharge permits.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with FAR 8.404(d).

In accordance with FAR 8.404(d), the ordering activity contracting officer has determined that the task order represents the best value to the government. The anticipated pricing is based on Stantec's established GSA Multiple Award Schedule (MAS) rates under Contract Number 47QRAA19D000Q, which have been pre-negotiated and determined fair and reasonable. These labor rates, combined with a pre-negotiated, GSA-compliant , ensure that the cost of the required services is consistent with commercial market standards.

Furthermore, Stantec's familiarity with the site and its ability to process purge water through the existing onsite groundwater treatment system (Building 52A) at no additional charge avoids costly waste disposal fees. The total estimated cost is fair, reasonable, and represents the best value to the Government.

6. A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

Market research was conducted via GSA Advantage under NAICS Code 541620 (Environmental Consulting Services). Although multiple schedule holders are listed on the FSS, Stantec is the sole contractor possessing both the localized environmental sampling infrastructure and the mechanical facilities maintenance capabilities required to operate the Building 52A treatment facility and pneumatic pump network. Procuring these combined services through Stantec prevents the administrative duplication and cost of administering two separate, disjointed procurements. Furthermore, Stantec's mature site-specific efficiencies translate into optimized labor hours, delivering immediate savings in both time and federal funds.

7. Any other facts supporting the justification.

None.

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made.

At this time, CFLHD will continue to monitor the federal schedule market to identify other environmental firms that develop similar specialized technical capabilities in pneumatic pump operations and localized groundwater remediation. Prior to subsequent acquisitions, the government will reassess the site's technological architecture and database configurations to facilitate broader commercial competition.

9. The ordering activity contracting officer’s certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

I certify this justification is accurate and complete to the best of my knowledge and belief.