Effectiveness and Efficiency of Defense Environmental Cleanup Activities of DOE's Office of Environmental Management Report 1 (2021) / Chapter Skim
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4 Project Management Policies, Processes, and Procedures
4 Project Management Policies, Processes, and Procedures
Pages 41-61
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From page 41... ...
. The chapter assesses Order 413.3B by comparing it against recognized industry standards and looking at its current application within the Office of Environmental Management's (EM's)
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From page 42... ...
This chapter considers the lessons learned from these two sites and their impact on DOE's path forward and choice of the IDIQ task order approach and the degree to which this approach can be linked with meaningful end states. OMB Circular A-11 and PMIAA Applicability This section discusses three areas where additional clarity and expansion would be beneficial, particularly in applying Order 413.3B to the EM cleanup program.
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, and disposal [italic added] ." Additional clarity in A-11 Appendix 1 Capital Programming Guide and DOE Order 413.3B, to clearly establish that all environmental resto ration that derives from the prior construction and operation of a capital asset is to be included in the definition of a capital asset as provided for in OMB Circular A-11, would be beneficial.
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From page 44... ...
FINDING: The applicability of Order 413.3B is to "capital asset projects" which DOE describes as being construction projects, major items of equip ment, and certain environmental cleanup projects. Projects less than $50 million total project cost are exempted.
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ASSESSMENT OF ORDER 413.3B COMPARED TO OTHER PROJECT MANAGEMENT STANDARDS The committee assessed DOE Order 413.3B against three reference systems for program and project management: • Project Management Institute (PMI) best practices (nine elements)
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FINDING: DOE Order 413.3B does not incorporate CII's best practices for advanced work packaging, materials management, planning for modulariza tion, or disputes prevention and resolution. Program Management • Portfolio and program management are not adequately addressed in Order 413.3B: -- Order 413.3B does not address the challenges, opportunities, and processes that affect project to project interfaces and efficient "end state" oriented program delivery.
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This is milestones and sufficiency now codified in the Demolition Protocolb criteria envisioned in best which the committee regards as a project practice (1) of PMI execution plan (PEP)
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• Management of multiple task order projects requires multiple scope development activities and negotiations. Scope development must be clearly linked to overall site outcomes in a manner that assures that missing scope is not just picked up in a subsequent task.
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Estimates at completion based on the cost-performance index are a floor to actual final cost given that program cost performance rarely improves as the program proceeds to its completion. • The committee in its next report will look at DOE's ability to deliver the cleanup mission utilizing its current approach to project and program delivery and likely levels of funding.
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CD-0 • Establishment of • Areas requiring further attention include: requirements is consistent Expanded basis of design with PMI best practice (2) established at CD-0, addressing • Program requirements technical, construction and document defining O&M considerations ultimate goals project • DOE should require project risk review by must satisfy, currently PMRC for all projects >$100 million at used by NNSA, would this stage, considering their involvement at improve EM linkage CD-1.
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planning at a much earlier stage than outlined in DOE Order 413.3B continued
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413.3B: Change 5, Washington, D.C., April 12. b DOE Office of Environmental Management, 2020, Office of Environmental Management Cleanup Project Management Protocol and Implementation Standard for Demolition Projects, EM Protocol, Final June 8, 2020, Washington, D.C.
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The second instance of EM's narrow interpretation and application of the DOE Order 413.3B is the exclusion, for example, of groundwater remediation. Here EM's position could be seen as inconsistent with OMB Circular A-11, Preparation, Submission and Execution of the Budget -- specifically the supplement, "Capital Programming Guide" -- which states, "Capital assets include the environmental remediation of land to make it useful" (OMB, 2016, p.
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with "adequate project management requirements, processes and procedures defined to enable project success," given their high percentage of capital asset projects that they do not perform per DOE Order 413.3B. The definition found in Section 3c(4)
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The latter include for example dispute prevention provisions that are discussed further in Chapter 6. COMPARISON OF ORDER 413.3B AND NEW PROPOSED CLEANUP PROTOCOL DOE presented its rationale for why the Demolition Protocol was needed and why the protocol is envisaged to be separate from Order 413.3B: EM often demolishes and disposes of facilities where the design elements common to construction may not be applicable.
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56 MANAGEMENT OF ENVIRONMENTAL CLEANUP ACTIVITIES OF DOE-EM TABLE 4.2 Assessment of Benefits and Challenges of Broader Application of Order 413.3B to EM Projects Coverage of Order 413.3B Benefits Challenges Increase Order 413.3B Generally represents best practice Increases the need for FPDs coverage for project management and should and associated PM staff be broadly applied within EM Requires a broad consistent to improve the overall quality of PM culture to be built project execution and the results across the sites obtained Requires a resource sharing Acts to strengthen the culture of culture to be built across project management required to sites to meet evolving EM deliver EM's mission priorities Requires strengthening of EM project support capabilities and potential elevation of these within the organization when program management needs are considered in the second part of our report Address relationship Strengthens links between to PMIAA and expand portfolio, program, and project coverage to address Creates defined linkage between relationship of programs and portfolio outcomes, program projects to portfolios end states (and defined portions thereof) , and projects including those awarded under a task order approach, if appropriate Clarify that scope of Ensures Order 413.3B coverage coverage includes capital of EM projects of all types within assets as defined in A-11, not established size thresholds just construction projects, including the full life-cycle, through environmental restoration, of projects related to a capital asset Explicitly recognize the Maintains EM as consistent circumstances that allow with Order 413.3B and can be for a combined CD-1,2,3 accomplished through the PEP approach process as contrasted with the inclusion of the protocol as an Appendix to Order 413.3B
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, point important given increased use of 3, as described previously IDIQ Reduce threshold for Order PEPs for small projects can adapt 413.3B applicability to Order 413.3B to improve project $20 million consistent with management systems and practices current pilot project in and build the broader project NNSA management culture that task order contracting requires. This would foster greater cross-site consistency of implementation of Appendix D
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From page 58... ...
Given the scale of the demolition challenge, it is possible that specific projects may exceed the $750 million threshold laid out for major systems projects that would otherwise require Deputy Secretary approval, whereas, in the Demolition Protocol, approval has been delegated to a lower organizational level (S4)
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From page 59... ...
Multiple-award contracts, such as is the case with EM's multiple contractor award for a national deactivation contract at the Paducah Gaseous Diffusion Plant, maintain effective competition throughout the acquisition. • EM's Demolition Protocol for demolition projects states, "Disaggregation of site program work into smaller, discrete work activities is encouraged as it provides better project definition and clarity, is more manageable, reduces time horizons and risks, and is consistent with the project man agement best practices found in DOE O[rder]
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Continue applying the requirements of Order 413.3B to M&O con tract work on capital asset projects -- the latter including construction projects, major items of equipment and cleanup projects; 3. Clarify the definition related to project performance found at Section 3c(4)
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______.2020. Office of Environmental Management Cleanup Project Management Protocol and Implementation Standard for Demolition Projects.
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