Original Date: 02/24/1997
Revision Date: 04/14/2003
Best Practice : Low-Level Radioactive Waste
The Army Industrial Operations Command (IOC) is the designated Executive Agency for managing the disposal, control, guidance, records, and reporting of the Department of Defense (DoD) Low-Level Radioactive Waste (LLRW). This function came about through the aggressive and innovative approaches implemented by the Command’s Radioactive Waste Disposal Division.
Low-Level Radioactive Waste requires compliance with stringent state and federal environmental regulations for safe disposal. Examples of LLRW managed by the IOC are gauges, medical waste, night vision devices, chemical detection instruments, engine components, missile components, laboratory waste, wrist watches, compasses, contaminated soils, exit signs, and smoke detectors. DoD LLRW represents 10% of the radioactive waste produced in the U.S. During the 1980s, DoD installations were cited for numerous incidents, accidents, and violations. DoD developed a reputation with regulators for having less than adequate practices and a large safety concern. In 1990, Congress tasked the General Accounting Office (GAO) to investigate the way the DoD managed waste, specifically LLRW. The GAO recommended the establishment of the DoD LLRW program to oversee the development of uniform policies and procedures; ensure compliance throughout DoD; and gain efficiencies of scale. Additionally, the GAO recommended developing one DoD-wide inventory, establishing consistent treatment techniques; working with State, compacts, and Federal regulators; and establishing outside continental United States (OCONUS) LLRW disposal.
In September 1992, the Army was designated as the Executive Agent for LLRW. The Radioactive Waste Disposal Division of the Army’s IOC was designed to implement an aggressive disposal program, following the GAO recommendations, through implementation of the following innovative practices:
Consolidation of Facilities: Established treatment centers for combining shipments, sorting and separating materials, reducing volume, and ensuring quality shipments to disposal sites. This practice lowers customer costs, avoids violations at disposal sites, and improves relations with States and compacts.
Use of Disposal Basic Ordering Agreements (BOAs): BOAs were established to avoid multiple contracts by combining all government disposal contracts.
8A Contracting: BOAs were established with small disadvantaged businesses. Ease and flexibility of BOAs with 8As allowed hand picking reliable contractors; ensured contractor capability/qualifications; and developed long-term relationships. 8A contractors have been ideal for small efforts and emergency responses, saving cost and delays in competitive bidding.
Qualified Bidders List (QBL): A QBL was established to solicit only pre-qualified contractors for performing decontamination and disposal, shipping, and treatment technologies. This practice limits competitive bidding to only pre-qualified contractors, thus shortening contracting lead-time and avoiding delays caused by unqualified contractors.
Combined Shipments: The practice of sweeping a geographical area to pick up waste at several installations resulted in reduced transportation, temporary duty, and contractor costs.
IOC Staff vs. Contractor: IOC staff is used in place of contractors on selected LLRW collections to stabilize the IOC workforce, provide savings to its customers, as well as provide oversight requirements for some collections. IOC also takes advantage of military vehicles for transportation through proper planning and coordination. Savings in 1996 for this practice exceeded $250,000.
Permit Initiatives: IOC negotiated the State and Interstate permits required for importing and exporting LLRW for the entire DoD, rather than the multiple permits that would be required if all installations applied individually. Each permit avoided saved an average of $500 per permit.
Waivers and Deviations: Waivers and deviations were requested from State Regulators to get a better deal for large disposal efforts. Examples included waivers and deviations for Mag-Thor Engines and Mag-Thor Missile scrap resulting in a combined cost avoidance of more than $1.7 million.
Support For Other Government Agencies: IOC provides a choice for other government agencies that do not have the expertise and the contracts in place to dispose of LLRW. Customers include United States Department of Agriculture, Veterans Administration, Federal Emergency Management Agency, National Aeronautics and Space Administration, United States Customs, Department of Justice, Environmental Protection Agency, Department of Energy, and the U.S. Geological Survey.
The Radioactive Waste Disposal Division, with a staff of 20 employees, currently services 143 sites annually. Their program avoids duplication of efforts; provides one voice to the regulators; increases responsiveness for LLRW disposal; lowers cost; and eliminates many violations and penalties. GAO recommendations have been exceeded. Customer satisfaction surveys rate the Division’s overall performance at 3.8 on a scale of zero to four.
For more information see the
Point of Contact for this survey.