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This is a Justification and Approval (J&A) document for a sole source acquisition under other than full and open competition authority.

The Department of Veterans Affairs, through Network Contracting Office (NCO) 10, seeks to award a contract for Project No. 552-26-102, Tunnel G Emergency Steam Repair at Dayton VA Medical Center. The Independent Government Estimate is $2,000,000.00. The project requires repair of deteriorated steam and condensate piping and failing supports over a 210-day period, involving demolition and removal of 900 linear feet of failed piping and supports, installation of 900 linear feet of new steam and condensate piping with stainless-steel supports and anchorage, hydrostatic testing, and restoration of tunnel, asphalt, and grounds. The work is critical because the affected section has been shut down due to rupture risk, and the lack of steam and heating services will impact five buildings: Building 115 (Out-Patient Psychiatric Services), Building 116 (Under Renovation), Building 118 (Medical Center Personnel), Building 119 (Medical Center Personnel), and Building 400 (Homeless Veteran Housing/Services). The justification cites unusual and compelling urgency under 41 USC §3304(a)(2) as the statutory authority for sole source procurement. Buckeye Industrial Piping LLC, located at 11422 Fields Road, New Carlisle, Ohio 45344-9468, is the sole source selected based on their prior experience completing similar repairs under contract 36C25024C0046 for section H of the system in FY24, their specialization in process piping, and existing facility knowledge. The Buy American Act and Trade Agreements Act apply without exception. The document includes certifications from the Energy Manager, Contracting Officer, Acting Division Chief, Acting Director of Contracting, and Executive Director of RPO Central confirming accuracy and approval.

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Request for Sole Source Justification Format >SAT

VHAPG Part 806.3 OFOC Page 1 of 3 Revision: 04 Effective Date: 12/15/25 Acquisition ID No. 36C250-26-AP-5140

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A)

For

Other Than Full and Open Competition (>SAT)

Acquisition Plan Action ID No. 36C250-26-AP-5140

1. Contracting Activity:

Network Contracting Office (NCO) 10

260 East University Avenue

Cincinnati, Ohio 45219-2637

Dayton VA Medical Center (VAMC)

4100 West Third Street

Dayton, OH 45428-9000

Purchase Request No. 552-26-4-6932-0106.

2. Nature and/or Description of the Action Being Approved:

Project No. 552-26-102, Tunnel G Emergency Steam Repair’s purpose is to repair the existing steam and condensate piping system. This section’s piping is deteriorated, and the supports are failing to support the system as a whole. The section has been shut down as continued operation presents a risk of pipe rupture, a complete steam-system shutdown and potentially catastrophic conditions. Until the repairs are made, no steam/heating services can be provided to the following buildings 115, 116, 118, 119 and 400.

The Independent Government Estimate (IGE) for this project is $2,000,000.00.

3. Description of Supplies/Services Required to Meet the Agency’s Needs:

Project No. 552-26-102, Tunnel G Emergency Steam Repair will have a duration of 210 days and complete all repairs needed. The work includes access through the parking lot and tunnel, demolition and removal of failed piping (900 LF) and supports, installation of new steam and condensate piping

(900 LF), installation of new stainless-steel supports and anchorage, hydrostatic testing, and restoration of all disturbed tunnel, asphalt, and grounds areas. Until these repairs are complete, no steam/heating services can be provided for the following facilities:

• Bldg. No. 115 - Out-Patient Psychiatric Services.

• Bldg. No. 116 - Under Renovation.

• Bldg. No. 118 - Medical Center Personnel.

• Bldg. No. 119 - Medical Center Personnel.

• Bldg. No. 400 - Homeless Veteran Housing/Services.

With fall and winter approaching, the lack of steam/heating services will impede direct patient care, facility operations and limit housing and services to the homeless veteran population. It is vital to the medical center the repairs are made, and the steam/heating services are restored.

VHAPG Part 806.3 OFOC Page 2 of 3

Acquisition ID No. 36C250-26-AP-5140

4. Statutory Authority Permitting Other than Full and Open Competition:

( ) (1) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency

Requirements per 41 USC §3304(a)(1) as implemented by RFO 6.103-1;

(X) (2) Unusual and Compelling Urgency per 41 USC §3304(a)(2) as implemented by RFO 6.103-2;

( ) (3) Industrial Mobilization, Engineering, Developmental or Research Capability or Expert

Services per 41 USC §3304(a)(3) as implemented by RFO 6.103-3;

( ) (4) International Agreement per 41 USC §3304(a)(4) as implemented by RFO 6.103-4

( ) (5) Authorized or Required by Statute per 41 USC §3304(a)(5) as implemented by RFO 6.103-5;

( ) (6) National Security per 41 USC §3304(a)(6) as implemented by RFO 6.103-6;

( ) (7) Public Interest per 41 USC §3304(a)(7) as implemented by RFO 6.103-7;

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition

Requires the Use of the Authority Cited Above (applicability of authority):

The time involved in competing and awarding the project would delay the repairs needed now and prolong depleted heating operations for the Dayton VA Medical Center.

Buckeye Industrial Piping LLC. is uniquely suited for this project. They completed similar repairs, under contract 36C25024C0046, for section H of the system in FY24. Buckeye specializes in process piping which is needed here. That specialization, prior experience and existing knowledge of the facility and the system make them an ideal partner to complete the urgent repairs and restore the facility to complete functionality.

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 RFO Part 5 and, if not, which exception under RFO Part 5 applies):

No effort was made to solicit offers from additional contractors. Buckeye Industrial is uniquely capable of the needed repairs, is already present onsite and ready to begin work.

An award notice and the justification and approval will be posted in accordance with regulation.

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and

Reasonable:

The CO will determine the cost for the repairs to be fair and reasonable prior to award. The CO intends to utilize the comparison of the proposed price to the IGE for that determination.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons

Market Research Was Not Conducted:

The SBA’s Small Business Search data was queried using NAICS code 238220. Located 39

SDVOSB and VOSB firms.

The BAA and TAA apply to this acquisition without exception.

Due to the urgent nature of the repairs needed, additional market research was not completed.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition:

https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-5 https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-5

VHAPG Part 806.3 OFOC Page 3 of 3

Acquisition ID No. 36C250-26-AP-5140

In addition to the urgency of this requirement, the requested repairs are minor in their scope compared to the entire system. This project replaces 900 LF of piping. The system itself has 13,980 LF in piping total. This project only addresses repairs needed on 6.4% of the total system.

10. Listening of Sources that Expressed, in Writing, an Interest in the Acquisition:

Buckeye Industrial Piping LLC

11422 Fields RD

New Carlisle, OH 45344-9468

11. A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers to Competition before Making subsequent acquisitions for the supplies or services required:

When repairs of this nature are needed, there is nothing that can be done to overcome barriers to competition. More routine repairs or a total system replacement in the future will provide for full and open competition.

12. Requirements Certification: I certify that the requirement outlined in this justification is a Bona

Fide Need of the Department of Veterans Affairs and that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Jason Dahal Date

Energy Manager

Dayton VA Medical Center

13. Approvals in accordance with the VHAPM Part 806.3 OFOC SOP:

a. Contracting Officer Certification (required): I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief.

Luke A. Turner Date

Contracting Officer

Julie A. Stout Date

Acting Division Chief/Branch Chief

Monae D. Heath Date

Acting Director of Contracting

Daryl A. Berg Date

Executive Director, RPO Central

Head of Contracting Activity https://dvagov.sharepoint.com/sites/vhapromanual/SitePages/VHAPM-Part-806.3.aspx VHAINDStoutJ Typewritten Text 9/9/2026

2026-09-09T10:49:33-0400
JASON DAHAL
2026-09-09T10:55:29-0400
LUKE TURNER
2026-09-09T11:03:25-0400
JULIE STOUT
2026-09-09T12:58:28-0400
MONAE HEATH
2026-09-14T07:17:44-0500
DARYL BERG

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