H.13 FAR Subpart 8.4 Limited Sources Justification (V1.4 11-29-2023) - Scully Fuel System - Redacted.pdf

UNITED STATES MARINE CORPS

MARINE CORPS INSTALLATIONS NATIONAL CAPITAL REGION

MARINE CORPS BASE QUANTICO

3250 CATLIN AVENUE

QUANTICO VIRGINIA 22134 5001

FAR Subpart 8.4 Limited Sources Justification

V 1.4 (29 Nov 2023)

MEMORANDUM TO THE FILE

Subj: FAR SUBPART 8.4 LIMITED SOURCES JUSTIFICATION

I. BACKGROUND:

A. FAR 8.405-6 states that orders placed, or BPAs established under Federal Supply Schedules are exempt from the requirements in FAR Part 6. However, an ordering activity must justify its action when restricting consideration. This memorandum documents the justification for limiting sources, in accordance with FAR 8.405-6(c).

B. This acquisition is conducted under the authority of the Multiple-Award Schedule Program (see

FAR 8.401).

II. IDENTIFICATION OF THE AGENCY AND CONTRACTING ACTIVITY:

This acquisition is being conducted by the Department of the Navy, under the Headquarters Marine Corps, Installation and Logistics (HQMC, I&L) Head of the Contracting Activity (HCA).

The executing contracting office is Marine Corps Installations National Capital Region - Regional Contracting Office (MCINCR-RCO), 2010 Henderson Road, MCB Quantico, VA 22134-5000.

III. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

Marine Corps Base Quantico (MCBQ) Motor Transportation Maintenance has a requirement for removing and replacement/install of two (2) Scully system dual level overfill protection system.

The Scully system will be used in conjunction with fuel farm fuel systems on MCQB to provide protection against overfilling of the fuel trucks and prevent the trucks form being driven without properly securing the fuel system.

The intent of this action is to issue a Sole Source order under GSA Schedule Contract No. GS- 07F-9612S, Scully Signal Company, current contract period 12 July 2006 – 31 July 2026.

The required delivery/performance start date is date of award.

IV. DESCRIPTION OF THE SUPPLIES OR SERVICES REQUIRED TO MEET THE

AGENCY’S NEEDS (INCLUDING THE ESTIMATED VALUE):

Marine Corps Base Quantico (MCBQ) Motor Transportation Maintenance has a requirement for removing and replacement/install of two (2) Scully system dual level overfill protection system.

The Scully system will be used in conjunction with fuel farm fuel systems on MCQB to provide protection against overfilling of the fuel trucks and prevent the trucks form being driven without properly securing the fuel system.

MCBQ requires a dual-level overfill protection system on fuel trucks to ensure safety, environmental protection, and operational efficiency. Overfilling fuel tanks can lead to hazardous spills, fire risks, and fuel wastage. A dual-level system provides two independent alarms—one at a high level and another at an overfill threshold—to prevent accidental overflow and allow operators to take corrective action before a spill occurs.

All mobile refuelers and defuelers placed in service or contracted shall be equipped with Overfill Prevention Equipment (OPE), ensuring safety and operational efficiency. The OPE system must include:

• Overfill prevention mechanisms

• Ground verification for secure fuel transfer

• Truck Identification Module (TIM) for system integration

The OPE system shall be an automatic, electronic, continuously self-checking system featuring dual-level overfill prevention, utilizing both high-level and high-high-level liquid sensing.

Compatibility with the fuel facility’s installed system is mandatory, and the OPE must also incorporate an anti-driveaway feature to prevent accidental movement during fueling operations.

Additional safety and functionality measures include:

• A pre-check feature to verify proper function of the automatic high-level shutoff system before fueling begins.

• A high-level liquid sensor as the primary shutdown method at the fill stand.

• A high-high-level liquid sensor as the secondary shutdown method, initiating tank valve closure and an audible alarm during truck-based fuel operations, including defueling.

Additionally, Marine Corps fuel management policies emphasize strict compliance with regulations to maintain accountability and prevent pollution. These requirements align with NAVAIR 00-80T-109, Aircraft Refueling Manual, which establishes the minimum operational standards for OPE systems in refueling operations.

The Government intends to issue a single Firm Fixed Price (FFP) order with fixed-price award.

The required base delivery/performance start date is within 60 days date of award.

The total estimated value for this procurement is $XXX. Marine Corps Operations and Maintenance (O&M) appropriations will be used to fund this requirement as outline in the table below:

FY25

O&M $XXX

Brand Name/Manufacturer

Part Number/Description QTY Unit Cost Extended Price

Scully Kit Navy Refueler, with Audible Alarm and Disceptor

Isometrics Non-Scully Equipment (Hardware/brackets & fuel line kits from Isometrics)

Scully Installation Cost (40 hrs. x $123.63 per hour)

Scully Travel 1 Scully Warranty (3years per quote) - - Total

V. THE DETERMINATION TO LIMIT SOURCES IS BASED ON THE FOLLOWING

AUTHORITY AND SUPPORTING RATIONALE (select all that apply):

A. ___ AN URGENT AND COMPELLING NEED EXISTS, AND FOLLOWING THE

PROCEDURES IN FAR 8.405-2 OR 8.405-3 WOULD RESULT IN UNACCEPTABLE

DELAYS (FAR 8.405-6(a)(1)(i)(A)):

The supplies or services are of such unusual and compelling urgency that the Government would be seriously injured unless the agency is permitted to limit the number of sources from which it solicits bids or proposals. Urgent requirements are supplies or services that will result in a work stoppage or are mission critical and the routine processing time would result in injury to the Government. The determination that the procurement for the above item/service is an urgent and compelling requirement is based on the following:

1. Date on which the requirement was first identified:

2. Required delivery date/period of performance:

3. Explanation of why delivery/commencement of services by the date mentioned above is required:

4. Market research:

B. X 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 (FAR 8.405-6(a)(1)(i)(B)) (select all that apply):

1. ___ RESTRICTIVE RIGHTS. The source has established proprietary rights, limited rights in data, patent rights, copyrights or secret processes in the item or service required.

2. ___ EXCLUSIVE LICENSING AGREEMENTS. The item or service is only available from the Original Equipment Manufacturer (OEM), or there is only one authorized distributor or technical representative for the OEM.

3. X OTHER REASONS.

Marine Corps Base Quantico (MCBQ) Motor Transportation Maintenance has a requirement for removing and replacement/install of two (2) Scully system dual level overfill protection system. The Scully system will be used in conjunction with fuel farm fuel systems on MCQB to provide protection against overfilling of the fuel trucks and prevent the trucks form being driven without properly securing the fuel system.

A dual-level overfill protection system on fuel trucks is a safety mechanism designed to prevent fuel spills and overfilling during loading operations. It typically consists of sensors that detect fuel levels and trigger automatic shutoff or alarms when the tank reaches a predetermined capacity.

Replacing such a system involves ensuring that the new components—such as electronic sensors, bottom retain sensors, electric sockets, and rack monitors—are correctly installed and calibrated to maintain safe fuel handling. Proper maintenance and troubleshooting are crucial to avoid faults like terminal errors or metering device failures therefore Scully .

The Scully Dual-Level Overfill Protection System enhances safety by providing two levels of monitoring—one for high-level detection and another for an emergency overfill shutoff. This system integrates with Scully’s Dynacheck® technology, which continuously self-checks the system to ensure proper operation and prevent failures. These systems are widely used in petroleum and chemical industries to maintain safe loading operations and prevent environmental hazards.

Scully overfill protection systems are known for their fail-safe technology and continuous self-checking circuitry, which set them apart from other brands. Here’s how they compare:

• Reliability: Scully systems use Dynacheck® technology, which constantly monitors the system for faults, reducing the risk of failures during fuel loading.

• Compatibility: They support multiple sensor types, including 2-wire and 5-wire optic sensors, making them adaptable to various tanker configurations.

• Safety Features: Unlike some competitors, Scully integrates ground verification and static grounding systems to prevent electrostatic discharge and fires.

• Industry Use: Scully is widely trusted in petroleum and chemical industries, with major clients like BP, ExxonMobil, and Delta Airlines.

• Alternative Brands: Other brands like Civacon and Dixon also offer overfill protection, but Scully’s self-checking technology and multi-point monitoring provide an extra layer of security

Here’s a comparison of Scully overfill protection systems with some of its competitors:

Feature Scully Civacon Dixon

Self-Checking Technology

Dynacheck® Continuous Monitoring

Limited Fault Detection Basic Sensor Monitoring

Sensor Compatibility

2-Wire & 5-Wire Optic Sensors Optic & Thermistor Sensors Optic Sensors Only

Ground Verification

Integrated Grounding System Separate Grounding System No Built-in Grounding

Feature Scully Civacon Dixon

Industry Use Petroleum, Chemical, Aviation

Petroleum, Chemical Petroleum, Industrial

Major Clients BP, ExxonMobil, Delta Airlines

Shell, Chevron Various Industrial Clients

Scully stands out with its Dynacheck® technology, which continuously self-checks the system for faults, ensuring maximum safety. Civacon and Dixon offer reliable alternatives, but they lack the same level of real-time diagnostics and ground verification. When choosing an overfill protection system, here are the most important features to consider:

• Self-Checking Technology – Systems like Scully Dynacheck® continuously monitor for faults, ensuring maximum safety.

• Sensor Compatibility – Check whether the system supports optic, thermistor, or capacitive sensors to match your fuel truck setup.

• Ground Verification – Essential for preventing electrostatic discharge, reducing fire hazards during fueling.

• System Integration – Ensure it can easily connect with existing fuel monitoring and loading rack equipment.

• Durability & Environmental Protection – Choose systems with weatherproofing for reliable performance in harsh conditions.

• Compliance & Certification – Look for industry certifications such as API 1004, UL-listed, or FM-approved to meet regulations.

Failing to replace the required dual-level overfill protection systems can lead to serious safety, environmental, and operational risks. Here’s what could happen:

• Fuel Spills & Environmental Damage: Without proper overfill prevention, fuel can overflow, leading to contamination of soil and water sources. This can result in costly cleanup efforts and regulatory penalties.

• Fire & Explosion Hazards: Overfilled tanks increase the risk of fuel vapors igniting, potentially causing fires or explosions. This is especially dangerous in military and aviation fueling operations.

• Operational Disruptions: Fueling operations may be halted due to safety violations, leading to delays in mission readiness and logistical inefficiencies.

• Regulatory Non-Compliance: The Marine Corps and other military branches must adhere to strict fuel management regulations. Failure to maintain compliant systems could result in fines or restrictions on fuel operations.

• Equipment Damage: Overfilled tanks can cause mechanical failures in fuel trucks and storage systems, leading to expensive repairs and downtime.

Replacing and maintaining these systems ensures safe, efficient, and compliant fuel operations.

C. ___ IN THE INTEREST OF ECONOMY AND EFFICIENCY, THE NEW WORK IS A

LOGICAL FOLLOW-ON TO AN ORIGINAL FEDERAL SUPPLY SCHEDULE ORDER

(FAR 8.405-6(a)(1)(i)(C)):

The original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA was not issued under sole-source or limited-sources procedures.

D. ___ ITEMS PECULIAR TO ONE MANUFACTURER (FAR 8.405-6(b)):

An item peculiar to one manufacturer can be a particular brand name, product, or a feature of a product, peculiar to one manufacturer. A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer.

VI. DETERMINATION THAT THE ORDER OR BPA REPRESENTS THE BEST VALUE:

The Contracting Officer has determined that the order or BPA covered by this justification will represent the best value to the Government. Fair and reasonable pricing will be determined in accordance with DoD Class Deviation 2014-O0011 using the proposal analysis techniques at

FAR 15.404-1.

VII. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AMONG SCHEDULE

HOLDERS:

A discussion of the market research conducted among schedule holders and the results, or a reason market research was not conducted, is included in Section V, above.

VIII. ACTIONS TAKEN TO REMOVE OR OVERCOME BARRIERS:

For the reasons set forth in Part III, the activity has no plans at this time to take action to eliminate the barriers that led to restricted consideration for the types of supplies/services covered by this justification; however, this will be reassessed during follow-on acquisition planning.

DFARS 208.405-6 and PGI 208.405-6 REQUIREMENTS: The subject order or BPA exceeds the simplified acquisition threshold and is a follow-on to an order or BPA for the same supply or services previously issued based on a limiting sources justification citing the authority at FAR 8.405-6(a)(1)(i)(B) or (C). In accordance with DFARS 208.405-6 and PGI 208.405-6, this limited sources justification includes a copy of the previous justification.

The approval authority has determined that the planned actions to remove any barriers that led to the restricted consideration cited on the previous justification were completed.