A16_-_JOFOC_v2_1.pdf

Last updated 5/8/2023

United States Department of the Interior

NATIONAL PARK SERVICE

CONTRACTING PROGRAM

JUSTIFICATION & APPROVAL FOR OTHER THAN FULL AND OPEN COMPETITION for

SIMPLIFIED ACQUISITIONS OVER THE MICROPURCHASE THRESHOLD (See FAR Part 2)

UP TO SAT

(See FAR 13.106-1)

Date: 8-May-2023

PR Number: TBD, See funds approval from Budget Christine Sterling, PMIS 316100 &

316101

1. Nature and/or description of the item/service being procured and its intended use (include the anticipated cost):

Repair propane leaks within the Cow Creek residential area and Stovepipe Wells residential area located within Death Valley National. There are several units that are in critical need of repair/replacement of propane lines. The following units need repair:

The Cow Creek propane system serves approximately 79 park housing units.

- 11 Cow Creek Housing Units

- 2 Cow Creek Duplex, Housing Units

- 1 Cow Creek Apartment,

- Cow Creek Library,

- Cow Creek CHP unit,

- Cow Creek School

The Stovepipe Wells propane system serves approximately 7 park housing units.

- 1 Stovepipe Wells Housing Unit,

- 1 Stovepipe Wells Duplex Housing Unit, and

- 1 Stovepipe Wells Master Mater

Each of these units are also all fully occupied. While only a limited number of houses have leaks this poses a Health and Safety emergency to all the houses located with these two areas. This is a situation that rises to the level of an emergency.

The work shall include all labor, supplies, travel costs, and equipment necessary to repair the propane leaks and infrastructure to a fully operational status.

Anticipated cost for the work is $40,606.50 based on the Class A Independent Government

Estimate. Repairs shall be completed within 30 of issuance of award.

2. Sole Source Justification rationale (Check one and explain below):

Only one responsible source.

X Urgent and compelling circumstances exist. It is of critical importance that the repairs / replacement of the propane lines is completed within 30 days of contract issuance. The current leaks are causing life safety issues. The leaks are also a potential fire hazard. The repairs are required to meets or exceeds life safety codes and national building codes as well as National Fire Protection Association

(NFPA) and Structural Fire Manager. The leaks were identified by leak detection “sniffers” during our monthly meter reads. If the work is not completed as soon as possible NPS could experience significant financial cost if housing unit was to ignite due to propane gas in the unit. There is also a potential for human injury the longer the issue is not fixed. The need for the requirement is of such an unusual and compelling urgency that the Government would be seriously injured if the agency did not pursue this contract under a Sole Source procurement.

Other

Shoshone Propane is very familiar with the propane systems in the park. Shoshone Propane is a small business contractor, registered in SAM.gov, and has both the capacity and capability to perform the repair to the propane infrastructure immediately.

The vendor has one of only a few contracts willing to travel to Death Valley National Park. Shoshone

Propane has performed work on other contracts and has the ability to coordinate and perform the infrastructure repairs quickly in order to fixed the significant safety issue.

Should this work not be undertaken, each day the propane infrastructure is not repaired creates serious harm to the Government because propane is a volatile gas that can explode creating sever damage and loss of life which poses a serious health safety hazard to staff and the Public.

3. Market Research.

Market research was not performed for this contemplated procurement because of the unusual and compelling urgency of the propane leaks and little confidence of the infrastructure conveyance system which has created an urgent circumstance. The COR relied on his familiarly with local contractors who have the capability to perform this requirement. A delay in award of a contract would result in serious injury, financial or other, to the Government, this includes potential for health impacts of leaking propane pipes, explosiveness of the gas to do harm, or serious injury maybe even death, potential for damage to property if there should be an explosion, and the lack of staff with the necessary skilled technical experience to complete repairs to the propane infrastructure and connections to the homes.

4. If this is a determination for sole source, the contracting officer certifies:

a. Only one source is available and an urgent and compelling circumstance exists.

b. The anticipated price will be determined fair and reasonable using the price analysis techniques described in FAR Part 13.106-3(a).

(Signature) (Date) 26-July-2023

Charles Thompson

Title: Chief of Maintenance

(Signature) (Date)

Caroline Bachelier Contracting Officer