Use of Historical EM Practices and Policies for Management of Cleanup Program and Address GAO Concerns - 20222
As Department of Energy (DOE) Environmental Management (EM) program policies and management practices are revised over time, it might be useful to periodically reflect on the DOE EM program's past to identify practices that have worked and those that might be appropriate for possible reuse in the future. An added impetus to examine alternative approaches is the recent Government Accountability Office (GAO) report entitled 'Nuclear Waste Cleanup - DOE Could Improve Program and Project Management by Better Classifying Work and Following Leading Practices.' The February 2019 GAO report states that EM categorizes most of its work in a way that does not adequately involve independent experts and DOE senior leadership. It also noted that EM has not followed leading practices for program and project management that could help keep the cleanup efforts on schedule and control costs. The GAO report recommended that EM, working with DOE Office of Project Management (PM): - Establish requirements and then assess EM's ongoing operations activities to determine if some activities should be reclassified as capital asset projects based on these newly established requirements. - Review and revise EM's 2017 cleanup policy to include program management leading practices related to scope, cost, schedule performance, and independent reviews. - Update the cleanup policy to require that earned value management (EVM) systems be maintained and used in a way that follows EVM best practices. - Develop a policy to ensure that work is categorized as level of effort (LOE) only in appropriate, specified circumstances, such as when work is not measurable or when measurement is impractical. - Integrate EVM data into EM's performance metrics for operations activities. To assist with improving program performance and implementing audit recommendations, this paper reviewed past successful cleanups such as Weldon Springs, Rocky Flats, Fernald, Ashtabula, Battelle Columbus (abs, and other historical resources and people with experience during the early years of EM program. As such, there are several past practices which may well be suited for reuse today. Some of these practices include: - In 1990's, as the DOE EM cleanup program, known as Environmental Restoration came into effect, the known cleanup scope at each geographic location or site was organized into four levels ranging from overall site-wide cleanup effort to the individual 'release sites', providing high granularity to the program. - The cleanup program was organized by geography (Northwest, Southwest, Eastern Area Programs, etc.). These 'sub-program' managers provided a degree of Headquarters oversight and management allowing upper management (EM-1, 2, and 3) to focus on major decisions and issues. - Budget levels at selected cleanup sites were funded above 'minimum-safety' levels to accelerate actual cleanup work. - Past practice utilized EVM techniques and uniform EM oversight over all discrete project-like activities, providing for a coordinated cleanup effort. - EM managed LOE activities using benchmarking and best in class management practice techniques to help manage costs. - EM managed and reviewed entire site cleanup baselines, not only individual projects, focusing on a successful overall outcome. - Sites had a 'Road map' or 'Management Action Plan' that provided the overall strategy or plan for that site's cleanup - this helped with understanding and coordination of efforts. - EM had a robust lessons-learned program and database to capture and transmit worthy ideas. - EM had well-structured cleanup baseline change control policies to control cost and schedule changes, at the contractor and higher Headquarters levels. Finally, some of the GAO observations may be valid, however it is not clear as to their extent. For example, for some operation types of work, the use of the Level of Effort (LOE) earned value method to track progress may be appropriate. Also, to ensure independence of thought, and to obtain useful insight on past practices, it may be suitable to have former EM employees to assist with understanding past practices or to verify that activities have been properly identified. (authors)