ROCK ISLAND ARSENAL, Illinois (March 14, 2023) – The Munitions and Industrial Base Directorate at Army Contracting Command – Rock Island partners with Headquarters Joint Munitions Command to execute disposal services for the Department of Defense Low-Level Radioactive Waste, also known as the LLRW Program.
Cindy Wagoner, contracting officer, stated that her team started supporting the LLRW Program in 2009, but the program was established prior to her arrival. Wagoner added that back then, the U.S. Army was the Executive Agent but recently transitioned to the Lead Agent.
Cyrus Turner, health physicist with JMC, said the Executive Agency came into existence in the early 1990s after the Government Accountability Office published a report which concluded that the DoD could benefit greatly from one agency managing its LLRW. The command selected for that mission was JMC.
“The Army stepped up and said that they will do it for the other branches, and as suspected, there is definitely a streamlined advantage for the other branches to use the capabilities of the Army’s program,” said Turner.
The Executive Agency formally became the Department of Defense Lead Agent in 2017.
Today, ACC-RI provides JMC access to waste disposal services using Indefinite-Delivery Indefinite-Quantity, known as IDIQ contracts. All requirements issued through this partnership are sole-sourced to 8(a) contractors: small disadvantaged businesses. Radiation protection is a field known as Health Physics and radioactive waste disposal can be a core qualification or competency of the companies within this industry.
The partnership follows a common process to get disposal services.
“The scope of the requirements and funding come from customers into JMC,” said Wagoner. “Whenever the customer has low-level radioactive waste that needs to be cleaned up or disposed of, they send those requirements to JMC. JMC puts together a requirements package and then sends it to ACC-RI.”
ACC-RI then solicits a request for proposal from one of the JMC-approved contractors. Much of the work is similar in nature, in that each requirement contains an itemized inventory of excessed or unwanted radioactive material. The inventories are typically common instruments or articles that the military services use, where the commodity itself has a small radioactive component. It is this small radioactive component that requires specific management prior to disposal and there are only a few disposal facilities in the United States that can receive LLRW.
Selection of the contractor is based on several factors, such as the location of the requirement and the type of waste that is being disposed of.
JMC approves each contractor before requesting ACC-RI to open an IDIQ contract.
“Initially, we look for the contractors to have either a Nuclear Regulatory Commission license, which is the federal license, or an Agreement State license which is issued by one of the states that operates its own licensing program under an agreement with the NRC,” said Turner.
JMC also requires the contractor to employ a broker with the skills related to low-level radioactive waste disposal.
“We review their qualifications annually,” said Turner. “If they are new to our program, we ask them to submit the qualifications of their broker initially and we look for very specific things.”
Although most of the requirements are inventories of common instruments and articles, the program handles waste that dates back to the 1940s and consists of the residual contaminants left over from testing some of the first atomic weapons.
Phil Kantor, contract specialist, explained that in the 1940s, some of the former naval bases in California had ships return after being near the testing of the bombs at Bikini Atoll in the South Pacific. During these tests, Navy ships were contaminated with radioactive material from the explosion and some of these ships were brought to the bases for decontamination. There is still ongoing identification, removal, remediation, and disposal efforts taking place at these bases.
In addition to these clean-ups, there are also disposal projects with wastes generated from the aftermath of the 2011 earthquake and subsequent tsunami in Fukushima, Japan. In 2011, U.S. ships and aircraft were contaminated with fall-out after the explosion of the nuclear power plant.
Kantor explained that if JMC didn’t have this partnership with ACC-RI, a lot of their requirements wouldn’t have as quick of a turnaround. The strategy for award is contemplated by requirement to execute it, both, quickly and efficiently.
An example of the need for expediency are requirements with low-level mixed waste. This type of waste is subject to a time limit in which the waste may be accumulated by rule of the Environmental Protection Agency. Kantor said this means the waste must be off site within a specified number of days, otherwise the requirements generator may fall out of compliance. When those requirements come in, we work to issue a task order and remove the waste before this deadline.
“If we didn’t have these contracts, the process would slow down and it would take longer to do things,” said Kantor. “There would be other avenues to do it, but it wouldn’t be as efficient.”
An example of efficiency under this partnership, are contracts that become what JMC calls multi-site “milk-runs.” Turner said that JMC sometimes coordinates with a few service branches to develop a “milk run” which are projects where a single conveyance, such as a truck, travels through-out a region and services several sites consecutively.
“We can identify and plan these multi-site projects together," said Turner. "ACC-RI offers us the flexibility to respectively create one contract for several inventories. Otherwise, if someone had to travel to each one of those sites to do a solo pickup, there is a cost associated with that. We can connect the dots while developing the scope and then select the best contractor to do it. This is a cost-effective option for several customers that have small inventories near each other.”
By supporting JMC, Kantor has touched the Health Physics industry which has increased his awareness of the important mission that he supports. Even though there is a limited number of qualified 8a contractors, and the program has evident ties to health and safety, the partnership continues to successfully provide services to customers across the DoD. The work requires high affinity for problem-solving, coordination, and administration to supply the best acquisition strategy for the Lead Agent and their respective customers.
“The overall success of the program revolves around both teams, JMC and ACC-RI, coming together to find creative solutions for customer demands across the DoD network”, said Kantor. “In short, the customer wants or needs their waste off-site and our teams are a one-stop shop to support their requirements in the most efficient and cost-effective manner possible.”
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