ID03 J and A - SRO Destruction Services - Redacted.pdf

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Control Number: KNOX-SAT-2025-0151

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Control Number: KNOX-SAT-2025-0151

JUSTIFICATION REVIEW DOCUMENT

FAR Part 13 Justification and Approval

Simplified Procedures for Certain Commercial Items

Program/Equipment: Destruction Services for Classified Documents at Indianapolis, Indiana for US Army Financial Management Command.

Authority: FAR 8.405-6(a)(1)(i)(B) Only One Source is Capable.

Amount: $109,794.43

Prepared by:

Contracting Officer: Ranetta Deramos Contracting Officer

Phone: 520.945.9143 Date:

E-mail: ranetta.m.deramos.civ@army.mil

Technical:

Requirements:

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Program Manager/Program Executive Officer:

Phone: 463.203.4693

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Control Number: KNOX-SAT-2025-0151

Small Business: Not Applicable. USAFMCOM has no small business advisor. This role would be completed by MICC Ft. Knox once form has been submitted for processing.

Legal Counsel:

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Control Number: KNOX-SAT-2025-0151

Option 3 28 September 2028 through 27 September 2029

$18.1K

Option 4 28 September 2029 through 27 September 2030

$18.1K

Estimated Total Price $110.4K FAR 52.217-8 28 September 2030 through 27 March

$9.6K

Estimated Overall Total Price $120K

5. Authority Cited: FAR 8.405-6(a)(1)(i)(B) Only One Source is Capable

6. Reason for Authority Cited: Sole Source authority requested to use Reworld in Indianapolis, IN for incineration services based on the following:

1. Only one vendor is available to perform requested incineration services within a reasonable geographical area. Next closest vendor is 250 miles away in Grand Rapids, Michigan (Kent County Waste to Energy Facility).

2. Ability for USAFMCOM SRO/U.S. Government to transport materials locally (Indianapolis geographical area) to keep transport distance and time on the road to a minimum to ensure regulatory requirements for control, access to, and destruction of classified materials using incineration, the preferred destruction method in according with Army regulation. A working day is typically 8 hours. It is estimated that loading the boxes onto the pallets, getting them prepped for transportation, and loading them into the government vehicle will take 2+ hours. This piece is unable to be prepped the day before as a pallet filled with documents will not fit through the door frame of the storage room housing the documents. As such, on the day of destruction services, each box must be manually carried out of the storage room and placed onto the pallet for loading and shrink wrapping.

Transportation to an Indianapolis facility will take up to 1 hour each way. That only leaves 4 hours on site for destruction services without accruing overtime.

As such, an acceptable radius for a vendor to perform these services is limited to within the Indianapolis area, not to exceed a 30-mile radius from the Emmett J Bean Federal Center where the documents are housed. This will allow for the maximum amount of destruction to occur while reducing risk of classified materials from being in transportation for an excessive amount of time. In accordance with Department of Defense Manual (DoDM 5200.01- V3), “An authorized person shall keep classified material removed from storage under constant surveillance.” Because classified material can never be left unattended by USAFMCOM SRO personnel throughout the requested destruction process, a viable contractor source for destruction must remain within a specific geographical radius. Risk to the government significantly

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Control Number: KNOX-SAT-2025-0151 increases the farther away from the USAFMCOM facility the materials have to be transported to, and the more logistical challenges are created to comply with DoDM 5200.01-V3 in terms of ensuring constant surveillance. Longer travel times and longer travel distances subject USAFMOCM SRO personnel and classified materials to the potential for transport vehicle mechanical issues, road hazards, traffic pattern delays, construction traffic delays/closures, etc. Per DoDM 5200.01-V-3, documents and other material identified for destruction shall continue to be protected as appropriate for their classification until actually destroyed. Further, classified information shall be controlled in a manner designed to minimize the possibility of unauthorized removal and/or access. Those potential vendors that would require longer travel times and travel distances significantly increase the risk that control over the documents could be compromised and increase the possibility of unauthorized access/removal based on the aforementioned logistical challenges. Based on the regulatory requirements, the USAFMCOM Special Security Office and Senior Intelligence Officer have determined that any potential vendor must remain within a 30-mile travel distance from the USAFMCOM facility.

3. The ability to provide constant control of the materials from the time they leave the SRO to the time the materials are physically destroyed at the vendor’s location. Reworld specifically will allow 2-person integrity and physically/visual control requirements to be maintained while the materials are on their facility.

4. Costs, efficiency, and effectiveness to meet total material destruction requirements using incineration as the preferred destruction method for destroying classified documents.

5. The Reworld facility in Indianapolis offers secure disposal solutions that allow for monitored and witnessed destruction to ensure materials are properly destroyed, and they specifically advertise their secure disposal services for destruction of sensitive and classified materials including paper documents.

Reworld will permit cleared Government personnel from USAFMCOM SRO to accompany materials throughout their facility from the time the truck arrives at their dock, materials are unloaded, transported by Reworld personnel on their property and within their facility, and dumped into the destruction hoppers that then feed the materials into the incinerator. Reworld will then support SRO cleared personnel to continue observing the process up to and including when the materials physically enter the top of the furnace feed which then incinerates the materials to ash. Reworld has expressed their ability to support the specific requirements of this request, and has historically

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Control Number: KNOX-SAT-2025-0151 done work with other federal agencies to include the DEA and FBI, assisting those agencies with the destruction of their sensitive materials, documents, etc.

In the event sole source is not actioned favorably, based on the unique nature of the USAFMCOM SRO operation and the very specific regulatory requirements surrounding the destruction of classified materials in a manner fully compliant with those regulatory requirements, the SRO will not be able to destroy classified materials in an urgent manner needed to comply with record-retention guidelines. This places a significant burden on the Government to maintain storage, control and security of such documents beyond the retention requirements specified.

7. Efforts to Obtain Competition: Market research was done in the geographical area to obtain all available competition as a starting point. Only one vendor is capable of completing this work. Furthermore, they are also the only vendor capable of completing this work within over a 200-mile radius. The next available vendor was roughly 250 miles away, well beyond a feasible driving distance for large amounts of classified materials.

8. Actions to Increase Competition: Not applicable. Market research was completed and only one vendor was found that meets destruction requirements in the required geographic location.

Market Research: Market research first included USAFMCOM SRO security personnel reaching out to fellow security personnel at secure military installations in the surrounding areas including Grissom Air Reserve Base (Peru, IN), Wright Patterson AFB (Dayton, OH), and Crane Naval Surface Warefare Center (Crane, IN). None of these facilities are able to provide mass-volume destruction services, and none of these locations utilize incineration. While a secure military installation would have provided great benefit to the government despite the logistical challenges potentially faced by USAFMCOM to transport materials to any of these locations, this is not a viable option due to these sites not having equipment to support the destruction of our materials. The next level scrub performed in market research included any vendor operating an incinerator for the destruction of solid waste that was in a pre-determined acceptable travel distance from the USAFMCOM facility. The range set in place was a 30-mile radius to minimize the amount of time the classified materials are in transit, and exposed to the risk of unintentional access. This geographical restriction also serves to logistically support constant surveillance of the materials during transport. Since these materials cannot be dropped off or released to any unvetted/unwitting persons based on security classifications, the location of the vendor must support a one-day turn-around to include all preparation for transport, actual transport to the vendor location, time at the vendor to destroy the materials, and return trip to home station. Through independent confirmation with the Indiana Department of Environmental Management (IDEM) Office of Air Quality representative, as well as a search of their Indiana Department of Environmental Management Virtual File Cabinet (which houses all

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Control Number: KNOX-SAT-2025-0151 and SSO to document the destruction of materials to other Federal agencies to include the Drug Enforcement Agency (DEA) and Federal Bureau of Investigations (FBI).

Reworld indicated that they do not currently hold any open GSA contract that USFMCOM could utilize (piggy-back off of), thus creating the requirement for USAFMCOM to secure our own contract direct with Reworld for both current destruction requirements as well as future/ongoing requirements over the next several years.

9. Interested Sources: Reworld Waste.

10. Other Facts: Not applicable.

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Control Number: KNOX-SAT-2025-0151

11. Technical Certification: I certify 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.

12. Requirements Certification: I certify 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.

Technical:

Requirements:

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price/cost to the Government for this contract action will be fair and reasonable. This determination will be made using Market Research and price analysis

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Control Number: KNOX-SAT-2025-0151

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

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Control Number: KNOX-SAT-2025-0151

Approval

Based on the foregoing justification, I hereby approve the procurement of destruction services on an other than full and open competition basis pursuant to the authority of Title 41 U.S.C. §1901(e)(2) as implemented in FAR 13.501(a)(1)(ii), sole source (including brand name) under the authority of the simplified procedures for certain commercial items. The estimated value of the new contract is $109,794.43 for a five-year (base and four one-year options to include FAR 52.217-8) period of performance from 28 September 2025 to 27 September 2030. The approval is subject to availability of funds, and provided that the supplies and/or services herein described have otherwise been authorized for this acquisition.