Contractors would not earn award feeon the value of scope growth, which usually amounted to 8–10% of the physical progress.The Navy established a front-end Contractor role similar to an
Trang 2Best Practices for Environmental
Project Teams
Trang 4Best Practices for Environmental
Project Teams
Stephen Massey
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Trang 6Chapter 1: Best Practices for Environmental Project Teams 1
Historical Overview of the Defense Environmental Restoration Program (DERP) and Lessons Learned 2
National Economic Stimulus 5
DoD Pressure to Decrease Studies and Increase Site Cleanups 5
Measuring Performance 6
DoD Contracting Obstacles to Accelerating Cleanup 7
DoD Component Competition 9
Single Technology Focus 9
“Silver-Bullet” Technologies 10
Poor Technical Document Quality 10
Bigger Is Better 11
DERP ER Programs Shifts Focus to “Site Closeout” 11
New DERP ER Emphasis on “Remedial Process Optimization” 12
“Red and Unsustainable Remediation?” 13
DoD Components Expedite Technology Optimization Policies 13
New DoD ER Acquisition Strategy 15
Shift in Government and Contractor Quality Management 16
Green and Sustainable Remediation 16
Contractor Environmental Project Team Challenges 17
Environmental Restoration Project Manager, Inc 19
Chapter Overviews 19
Chapter 2: Understand Your Government Client Business Model 23
Business Model Elements 23
Constructing the Government ER Service Provider Business Model 24
NAVFAC Environmental Restoration (ER) Service Provider Business Model 25
Federal Requirements that Establish Basis for Environmental Restoration Programme 25
Programme policies 26
Navy Environmental Restoration Process and Progress Reporting Metrics 26
v
Trang 7Navy Programme Progress Reports and Execution Plans 29
Navy Guidelines for Achieving Site Closeout 29
Navy ER Work Groups and Programme Initiatives 30
Green and Sustainable Remediation 32
Client Contract Vehicles for Procuring Environmental Restoration Services 33
Chapter 3: Implement a Flexible Environmental Quality Management System 35
Features of a Flexible Company EQMS 36
Company Level 36
Programme Level 39
Project Level 41
Contractor QA and QC Staffing 43
Performance-Based Program/Project Tutorial 45
Quality Control Plan 48
Work Processes 48
Monthly QC Report 49
Project Website 53
Functional Inspection Plan 54
FIP Implementation 55
Government Performance Assessment 56
Sample Project Performance Evaluation Policy 58
Chapter 4: Develop and Utilize User-Friendly Project Websites 61
Brief Synopsis of Microsoft SharePoint 61
Fine-Tuning the Role of Collaborative Project Websites: Simpler is Better 66
Understanding the Perception of Website Value from the User Perspective 67
Company Operations Managers 67
Customer RPM 68
Company Resource Organization Managers 69
Program Managers (and Project Management Office Managers) 69
Project Managers 69
Project Team Members 70
Website Organization 72
Obtaining your Project Websites 73
Project Websites Improve the Efficiency of Teaming 73
Project Website Templates 75
Key Website Features 76
Project Correspondence Log 77
Company and Client Policies that Prohibit Public Access to Project Information 81
Identify Website Location: Intranet or Extranet The Extranet Options Might be Provided by Your Company, and is the Only Option Provided by a Web-Hosting Provider 83
Trang 8Which Project Team Members Will Function as
“Site Administrators?” 84
Three-Tier Website Structure: PMO, Base, Project Task Orders 84
Organize Project Website to Support Work Plan Development and Other Submittals Required Prior to Field Mobilization 85
Develop the Website “Required Records List” for the Project 86
Teach People How to Map the SharePoint Project Website to Their “My Network Places”, and Use Web Folders Option to Manage Files 89
Assist Analytical Laboratories with SharePoint 90
Partner with Your Government RPM to Provide Private Web Pages to Regulatory Agencies 90
Be Patient with Operations Managers and Other Senior Managers 91
Provide Project Team Members with Three-Ring Binders 92
Chapter 5: Developing Superior Proposals 95
Contractor Challenges 96
Lack of Awareness of Client Execution Plan 97
Limited Pre-RFP Activities 97
Lack of Time to Prepare a Proposal 99
Difficulty Defining and Estimating Project Scope 100
Lack of Time for Competitive Bid Process 100
Obtaining Internal Risk Board Approval 101
Providing a Competitive Price 101
Government Land Mines 102
RFP Language that Shifts Legal Risk to the Contractor 103
How Governments can Improve the Prices and Value They Obtain on Fixed-Price, Performance-Based MACs 112
Government Goals 113
Best Practices 122
BCT Culture Influence on Base Capture Plans 122
Contractor Base Capture System 124
Base Capture Plans 125
Site-Specific Capture Process 127
Proposal Development Process Improvement 128
Learn How Each Government Environmental Service Provider Agency Evaluates Proposals (Grading Process) 128
Avoid Using Proposal Content Boilerplates 133
Understand and Effectively Implement the Discriminator Discipline 134
Learn How to Feature the Most Important Win Theme: Flexibility 140
Design Proposal Sections in an “Evaluator-Friendly” Format 143
Replace the Popular Proposal Development Rule “Feature–Benefit–Proof” with “Feature–Benefit–Caused By–Proof” 144
Trang 9Chapter 6: Develop Superior Project Work Plans 147
The Five Predictable Stages of the Contractor Technical Document Quality Learning Curve on Major Environmental Restoration Programs 153
Contract Start up (Time Frame: Basic Contract Award Through Month 6) 153
Cause Drivers 154
Problem Recognition by Client (Month 6–9) 154
Cause Drivers 155
Contractor Response and Recovery Plan Development (Month 9–12) 155
Cause Drivers 156
Improvement Phase (Month 12–24) 156
Cause Drivers 157
Breakthrough (Month 36–60) 157
Cause Drivers 157
Summary 158
Lessons Learned and Best Practice Recommendations for Contractors 159
Screen New Employee Candidates for Their Technical Writing Skills 159
Accurately Estimate Work Plans and Other Technical Documents 160
Approach Technical Documents with the Same Degree of Commitment as Proposals 162
Sample Project Work Plan Development Interfaces 163
Sample Work Plan Development Process Flow 165
Inadequate Project Manager Planning Usually Leads to Various Inefficiencies 166
Managing Technical Document Development (Assignments, Tracking, and Status) 169
Technical Document (and Work Plan) Process Development Guidelines 172
Technical Authorship and Reviewer Guidelines During Document Preparation and Technical Reviews 174
Guidelines for Executive Summary for Final Reports 175
Establish Final Report Structure, Content, and Assignments Before the Project Mobilizes 177
Leadership Commitment 177
Chapter 7: Implement Rigorous Scope Management Tools 179
Process Overview 183
Base-Wide Risk Register 186
Project Scope Register 186
Scope Variance Communication Log 188
Contract Scope Mutual Understanding Meeting 190
Key Takeaway Points: Flexible Project Scope Management 191
Why are Government ER Service Providers Using These Fixed-Price, Performance-Based Multiple Award Contracts (PB-MACs) on Poorly Defined ER Scopes? 192
Trang 10Award Fee Is Not a Project Team Motivator 193
Base Tenant Clients Tend to Be Naı¨ve with Project Scope 194
The Critical Importance of Timely Notification in Response to Problems 195
Role of the Field Work Variance 196
Field Work Variance Process 197
Request for Information 199
Managing Scope on Government Cost-Reimbursable Contracts for Environmental Remediation Services 200
Hypothetical Case Study: The Production-Driven Contractor 200
Misconception: Cost-Reimbursable Contracts Make It Easier to Manage Scope 205
Chapter 8: Effectively Control Field Work 207
Option 1: Develop Simplified QC Plan Based on a Popular Quality Standard 208
Option 2: Try Implementing the Three Phases of Control 208
Welcome to Environmental Project Work 211
Three phases of control¼ Three phases of effective supervision 212
What do my supervisors do? 212
What is a supervisor according to the Ontario ministry of labour? 213
Break the project scope into tasks 213
Develop, Implement, and Improve Checklists 218
Project Task Leader Involvement, Assignment, and Turnover 219
Project Organization 222
Lean Contractor project organizations 222
Task Leader QC Involvement 224
Guidelines for assigning Task Leader/QC/SSHO Specialists 225
Procedures for Performing the Three Phases of Control 226
QC Documentation 228
Project QC Forms that Support the Three Phases of Control Process 229
Preparatory Phase Checklist 229
Common Pitfalls 229
Sample Project Team Interfaces 230
Effectively Planning and Implementing the Three Phases of Control for Subcontracted Work 232
Chapter 9: Implement Cause Analysis to Generate Solutions 235
Practical Applications for Cause Analysis on Environmental Projects 238
Quality Control and Quality Assurance 239
Safety 240
Project Management 240
Response to Client Contract Deficiencies 241
Proposal Development 241
Screening Issues for Significance 242
Root Cause Analysis Misconceptions 244
Role of Cause Analysis in Risk Management 245
Trang 11Cause Analysis Methods 246
Cause Analysis Fundamentals 248
Step 1: Define the Problem 248
Step 2: Map Causes 251
Step 3: Identify and Implement Solutions 258
Hypothetical Case Study: Expansion Joint Rupture 259
Understanding Ishikawa (Fishbone) Diagram Limitations for Cause Analysis 259
The Influence of Culture on Project Team Actions and Inactions 260
How Environmental Project Cultures Evolve 261
Client Project Managers Develop Loyalty Towards the Contractor Project Manager and Project Team People: Not the Company Brand 262
Cultural Factors Commonly Emerge During Cause Analysis 262
Role of the “Mental Risk Register” 263
Mechanistic Approaches to Work 264
Base Cleanup Team Culture 265
Hypothetical Case Study: Hazardous Waste Treatment Plant 268
Sample Cause Analysis Plan 271
How to Build Higher Level Support for Cause Analysis 272
Introductory Cause Analysis Awareness Training 272
Chapter 10: Design User-Friendly Work Processes for Project Teams 275
Process Attribute Descriptions 277
Helps Company Qualify for Contract Opportunities 277
Enables Program and Project Teams to Pass Audits 278
Protects Company from Litigation 278
Provides Users with Timely Recognition of High Risk Conditions and Unacceptable Results (e.g Information and Data) 279
Captures Performance Improvement Metrics 281
Process Ownership by Program or Project Team 283
Effective Processes Shift Focus from Procedure Narrative to the Process Summary and Procedure Components 285
Five-Phase Process Design Improvement Approach 288
Phase 1: Segment Procedure Components into Separate Document Control Units 288
Phase 2: Priortize Procedures for Improvement 290
Phase 3: Improve Forms or Checklists (for Each Process) 290
Phase 4: Create Process Summary (for Each Process) 292
Phase 5: Improve Procedure Visuals and Training Aids 292
User-Friendly Work Packages 293
Index 297
Trang 12Best Practices for Environmental
Project Teams
continuously improve competitiveness and performance on environmental restoration (ER)projects This book is primarily directed at project team members such as Project Managers,Engineers, Geologists, Chemists, and resource staff who support one or more project teams(e.g QC Managers, Health and Safety Managers) Best practices described in this book can beimplemented by smaller Contractors who directly compete with larger Contractors They canalso help specialty subcontractors seeking to team with large or small prime Contractors.Contractor-perspective insights can help Government Environmental Restoration ServiceProviders obtain lower prices and better value for their ER funds, and help regulatory agenciessupport ER continuous improvement
The United States Department of Defense (DoD) is the most influential driver of change,competition, and continuous improvement in our industry They are the largest global buyer of
ER services For over three decades, they pushed the “bleeding edge” of ER cleanups within thecomplex and rigid legal framework DoD has amassed the most global experience in theirongoing pursuit of best value cleanup They have spent billions of public tax dollars over thistime period Through 30 September 2009, DoD identified 21,333 Installation RestorationProgram (IRP) sites and 86% of these sites are designated as “Response Complete” [DefenseEnvironmental Restoration Program’s Annual Report to Congress, Fiscal Year 2009 (April2010)] DoD estimates the cost-to-complete (CTC) for IRP sites to be 6.4 billion USD and3.8 billion USD for the emerging Military Munitions Response Program (MMRP) cleanup.This body of experience represents thousands of mistakes and lessons learned
In 2002, DoD Component agencies (e.g Air Force, Army, and Navy) tasked with ER beganchanging their acquisition strategy to foster broad competition for contracts They continuouslyimproved their methods of contracting to obtain lower prices for services and began
shifting risk to Contractors The increasing competition to win contracts led to lower Contractorbids, much leaner project team staffing, lower profit margins, and higher risk One projectplagued with problems and cost overruns can quickly erase the profits from several projects thathave achieved project objectives and satisfied the customer Contractor senior managers arenow asking, “How can we win more contracts and avoid disaster projects that erase slim profitsfrom other projects?”
Best Practices for Environmental Project Teams DOI: 10.1016/B978-0-444-53721-8.00001-4
# 2011 Elsevier B.V All rights reserved.
1
Trang 13This book summarizes ER best practices based on lessons learned over a 15-year period, from
my DoD Contractor perspective as a practitioner at the programme management level.Collectively, the ER Contractor community contributed to accelerating the DoD learning curvewith numerous mistakes and process improvements We have made more mistakes in ourindustry than any other global industry in the world – not because we are less capable orcommitted to success We work in the most complex industry in the world Variability is thenorm, which is why experienced DoD ER Remedial Project Managers (RPMs) are the mostskeptical professionals in the world Beware of the Contractor proposal that assumes everythingwill go as planned Each ER project is different due to the complex mix of variables (contracts,regulatory requirements, contaminants, geology, and technologies)
U.S taxpayer funds have been put to good use Our ecosystem is a safer and cleaner place due
to our life-long contributions and commitment to continuous improvement Other
Governments, their Government ER Service Provider organizations, regulatory agencies,project teams, and academia can capitalize on lessons learned and best practices featured inthis book This chapter provides a historical overview of the Defense EnvironmentalRestoration Program (DERP) and lessons learned, including editorial viewpoints from myContractor perspective It concludes with a summary of environmental project teamchallenges and best practice topics covered by Chapters 2 through 10
Historical Overview of the Defense Environmental Restoration
Program (DERP) and Lessons Learned
The United States Department of Defense (DoD) began their Defense EnvironmentalRestoration Program (DERP) in the 1980s under the Installation Restoration Program TheDoD Environment, Safety, and Occupational Health Network and Information Exchange(DENIX) website contains a comprehensive library of historical documents This section draws
learned from my Contractor perspective The DoD has done an outstanding job of documentingthe DERP journey
The DERP Annual Report to Congress, FY 1997, contains a graphic that describes the
“Evolution of the Defense Environmental Restoration Program” (see Figure 1.1) In previousdecades prior to the 1970s, the DoD, along with the United States Department of Energy (DoE),was polluting their facilities, land, and groundwater with the same lack of awareness as manycorporations
a
http://www.epa.gov/history
Trang 14research, monitoring, standard-setting, and enforcement activities to ensure environmentalprotection EPA’s mission is to protect human health and to safeguard the natural
environment – air, water, and land – upon which life depends For more than 30 years, the EPAhas been working for a cleaner, healthier environment for the American people”
In 1980, Congress passed the Comprehensive Environmental Response, Compensation, andLiability Act (CERCLA), also known as Superfund This law requires responsible parties
to clean up releases of hazardous substances in the environment The 1986 SuperfundAmendments and Reauthorization Act (SARA) refined and expanded CERCLA, and formally
U.S Environmental Protection Agency (EPA) established
Secretary of the Army designated as the executive agent for FUDS properties
Early years of DERP: period of tremendous change and reaccomplishment of previous studies to meet new statutory requirements
DERP matures: period of rapid growth, lessons learned, accomplishments, and accelerated strategies and initiatives in response to base closures
Maintaining DERP momentum and stability with reduced funding: development and application of
a risk-based approach to sequencing work
Successful devolvement of DERA funds from the Office
of the Secretary of Defense to individual Components (except the Defense Logistics Agency and the Defense Special Weapons Agency)
Resource Conservation and Recovery Act (RCRA) enacted
Environmental Legislation and Regulations
DoD Activities
CERCLA enacted
Executive Order 12316 signed, delegating responsibility for conducting CERCLA response actions to federal agencies
Hazardous and Soild Waste Amendments enacted (amended RCRA)
SARA enacted (formally established DERP)
Executive Order 12580 signed, delegating CERCLA authority to DoD
Defense Base Realignment and Closure Act of 1988 and 1990
National Oil and Hazardous Substances Pollution Contingency Plan revisions promulgated
Oil Pollution Act revisions promulgated
National Defense Authorization Act of
1997 enacted, requiring devolvement of DERA funds
The Road
to Site Closeout
Figure 1.1 Evolution of the Defense Environmental Restoration Program.
Trang 15established DERP and funding for the programme through the Defense EnvironmentalRestoration Account (DERA).
RCRA and CERCLA were written before any significant DoD and industry ER site cleanupexperience was gained The popular U.S slang expression for this is “putting the cart ahead ofthe horse” U.S laws are drafted and available for public comment However, at that time,nobody knew if the environmental legal framework would enable an efficient process andapproach for implementing site cleanups Strict Government and Contractor compliancewith these laws paved the way for project work plans that would be voluminous, detailed,inflexible, and costly to change The laws required an interactive process with various time-consuming regulatory agency document reviews The laws also required public involvementand comment Nobody would disagree with the necessity of engaging public involvement But
it adds more time to the process Government attorneys review documents before they areprovided to the regulatory agencies The legal process is rigid, time-consuming, and assumes astatic and predictable site cleanup process
During the 1980s, Congress recognized that DoD no longer needed some of its installations andsubsequently authorized five rounds of base realignment and closure (BRAC) in 1988, 1991,
1993, 1995, and 2005
DoD activities from 1975 to 1995 focused on searching for contaminated properties, studyingthe problems, and writing reports Figure 1.2 shows the level of funding from 1984 to 1997,including the amount funded to BRAC
Figure 1.2 The level of funding from 1984 to 1997 Source: Defense Environmental Restoration
Program Annual Report to Congress, FY 1997.
Trang 16National Economic Stimulus
The multi-billion dollar projected cost-to-complete DoD and DoE cleanup that emerged in thelate 1980s and early 1990s created a new “environmental cleanup industry” that attractedseveral large corporations Corporations and small businesses made substantial investmentsinto “innovative site cleanup technologies” At that time, the industry had an aura of
“gold-rush” prospecting because Government and corporations were looking for “silver-bullet”technology remedies Many optimists perceived that if the United States can put a man on themoon, then certainly we could meet the challenge of developing innovative technologies toclean up contamination A variety of speciality subcontractors and analytical laboratoriestargeted the growing ER industry Rapid economic growth corresponded with cyclicaldownturns and downsizing in domestic industries, such as petroleum exploration, nuclearpower plant construction, and aerospace National symposia and conferences attractedscientists, engineers, and regulatory professionals from other countries who were
committed to cleaning up contaminated sites
Universities were caught off guard by the rapid emergence of the environmental cleanupindustry Good professional salaries, interesting projects, extensive research and development,and working outdoors in scenic locations offered very appealing career opportunities forscientists and engineers The resultant high corporate demand lured many scientists andengineers to join companies that were positioning their capabilities and resources to help clean
up the environment Professionals who transferred from other industries leveraged theirexperience and college educations in Geology, Chemistry, Engineering, and Biology To thisday, very few senior professionals in our industry began their college education with the goal ofdoing this type of work, and most take pride in contributing to a cleaner earth
DoD Pressure to Decrease Studies and Increase Site Cleanups
In the mid-1990’s, the U.S Congress, public, and communities threatened or impacted bycontaminated DoD properties thought too much funding was being spent on “studies” and notenough on “site cleanups” The DERP was under pressure to transition the
Program Annual Report to Congress, FY 1995, contains the following quote from
President Bill Clinton:
“Environmental experts from EPA, DoD, and the state will work together, and a
professional cleanup team will be stationed at every site.”
–President Clinton, July 1993
describes a series of monumental changes to the DERP, such as “Accelerating Cleanup”,
Trang 17“Fast-track Cleanup Moves Ahead”, and “Strengthening the Program” DoD published
Successes and Challenges, 1993–1995
Measuring Performance
DoD developed “Measures of Merit” to measure progress towards goals Newly
developed measures provided crucial feedback needed to develop and adjust programmerequirements and budget projections, as well as determine whether established goals reflectedfiscal reality
Three separate categories of Measures of Merit were developed to assess site remediationprogress from one discrete time period to the next, generally at the end of each fiscal year:Relative Risk Reduction This measurement applied only to DERA and BRAC sites thatwere ranked using the relative risk site evaluation framework DoD classified sites ashaving a high, medium, or low relative risk; response complete; or no further actionrequired
Progress at sites Gauging the progress of restoration efforts was still a critical measurethat required status reports on particular phases of investigation, design, cleanup, orresponse complete determinations at specific sites
Milestones Accomplished This Measure of Merit tracked the number of sites where cleanupaction had been taken and relative risk had been reduced in one or more media Thismeasure of merit was applied to sites funded by both the DERA and BRAC accounts toprovide another view of the progress in the restoration programme
Measures of Merit allowed DoD to more accurately measure and report progress towardscleanup goals as well as fundamental efforts to protect human health and the environment.Measures of Merit were hailed by DoD as a “breakthrough initiative that greatly enhancedDoD’s ability to monitor the performance and progress of the restoration program”
Figure 1.3 is a common graphic used by DoD to show the relationship between DoD
Installation Restoration Program Phases/Milestones with EPA CERCLA Phases/Milestones.(Defense Environmental Restoration Program Annual Report to Congress, FY 2009.)DoD ER performance metrics were inconsistent with EPA performance metrics DoD,under significant pressure to accelerate cleanup and demonstrate progress, forged aheadwithout EPA The only measures that had merit from the EPA perspective were thoseestablished by law: CERCLA and RCRA Table 1.1, compares DoD, RCRA, and
CERCLA Phases, Milestones, and Terminology It shows the inconsistencies that existbetween Remedy-in-Place and Site Closeout Note how “Site Closeout” is not recognized
by CERCLA
Trang 18DoD Contracting Obstacles to Accelerating Cleanup
From 1994 to 1999, DoD components (Army, Navy, and Air Force) felt significant publicand congressional pressure to transition a higher percentage of their ER budgets from studies
to site cleanup Each was using large cost plus award fee (CPAF) contracts to execute thesite cleanup phase on their multi-billion dollar environmental restoration programmes
Government paid the Contractor to establish a Program Management Organization (PMO)
to interface with the Government and assist with accelerating studies to cleanup
DoD Component ER Service Provider organizations were approaching site cleanup with aconstruction industry model, which backfired miserably on ER projects The constructionmodel caused sites to get bogged down in the study phase due to the substantial time and effort
technical packages for site cleanup (e.g reports, design drawings, maps, and specifications).Many technical packages were impressively well written, elaborate packages based on a limitednumber of analytical samples that were unrepresentative of site contamination (e.g plumecharacteristics) The cleanup phase was commonly based on numerous erroneous technical
Figure 1.3 DoD CERCLA environmental restoration phases and milestones.
Trang 19assumptions regarding the type and volume of site contamination, and many CPAF contractsexperienced continual scope changes and scope growth Contractors would not earn award fee
on the value of scope growth, which usually amounted to 8–10% of the physical progress.The Navy established a front-end Contractor role similar to an Architect–Engineer (AE), known
as the CLEAN Contractor, to investigate and characterize the site, and then (if sites required
Table 1.1 Comparison of DoD, RCRA, and CERCLA Phases, Milestones, and Terminology DoD IRP Phases/Milestones
Site Discovery
PA/SI Completion
Remedial Investigation (RI)
Interim Remedial Action
Relative Risk Reduction
Feasibility Study (FS)
Record of Decision
Remedial Design (RD)
Remedial Action (RA)
Remedial Action Construction
(RA-C)
Remedy in Place (RIP)
Last Remedy in Place (LRIP)
Response Complete (RC)
Long Term Monitoring Post Closure Permit
NPL Deletion Operation and Maintenance Five Year Review as needed Post-Closure Permit Expiration Corrective Action Process
& Maintenance (O&M) [depending on remedy]
Final RA Report [individual sites/OUs] or NPL Site Completion/Final Close Out Report [all OUs/entire installation]
Remedial Action Start through Completion
Remedial Action Start
Closure Plan Implementation and Groundwater Cleanup
Remedial Design (RD)
Closure Plan Approval and Post Closure Permit Issuance
Statement of Basis/Corrective Action Decision (CAD)
Record of Decision Public Comment
Feasibility Study (FS) Closure Plan Corrective Action Plan (CAP),
Corrective Measures Study (CMS)
Interim/Stabilization Measures Interim Remedial Action (IRA)/
RCRA Facility Assessment National Corrective Action Prioritization System (NCAPS)
Hazard Ranking System (HRS) National Priorities List (NPL)
Preliminary Assessment/Site Inspection Completion
EPA RCRA Phases/Milestones Closure and Post-Closure Permits
(Waste in Place)
Corrective Action
Source: Department of Defense
Reporting Conventions (Restoration
Management Information System;
Management Guidance for DERP)
Source: 40 CFR Chapter I, Parts
(COULD INCLUDE REGULATED UNITS)
EPA CERCLA Phases/Milestones
Trang 20cleanup) develop technical package deliverables for the Navy (design drawings, maps, plans,specifications) CLEAN was a misnomer acronym because the role resembled STUDY – not sitecleanup The Navy bundled the technical package deliverables in the Request for Proposal(RFP) for a separate Remedial Action Contract (RAC) The CLEAN as AE role quicklychanged when the Navy realized the approach consumed too much time and lacked flexibility.For example, the time and effort required to characterize the site and develop the technicalpackage deliverables commonly exceeded the time and effort to clean up the contaminated site.Thus, the RAC Contractor role evolved into a design–build Contractor for site cleanups, and thescopes of work for cost-reimbursable cleanup evolved to become “performance based”.Performance-based contracts did not prescribe “how” to clean up sites They contained enoughsite characterization information for the RAC Contractor to develop design–build technicalpackages and work plans, supported by technical assumptions to define contract scope,contamination types, and quantities RAC Contractors started to augment their construction-oriented workforce with scientists and engineers to review site characterization data, evaluatetechnology options, and develop work plans for design–build field execution The Navyemphasized getting into the field By giving the RAC Contractor design–build freedom andresponsibility, site cleanups could be started sooner Also, removing the AE oversight roleenabled the Navy Remedial Project Managers (RPMs) to deal directly with the RAC
Contractor Costly contract modifications and change orders were minimized
DoD Component Competition
The U.S Government DoD Component Service Provider (Army, Navy, and Air Force)competition started on 1 October 1996, when DoD Components became responsible for
Restoration Program, Annual Report to Congress (FY 1997) documented the competition withindividual DoD Component reporting supplements, each entitled “DERP FY1997 ReportCompetition – (Insert DoD Component Name) Cleanup Status and Progress” Each reportedtheir cleanup progress relative to the same metrics
This competition was excellent timing for Contractors anxious to start site cleanup The
DoD components were under substantial pressure to start cleaning up sites They listened
to Contractor recommendations on how to streamline the studies and accelerate the schedule
to start cleanup Along the way, Contractors and the Government learned some tough lessons.Single Technology Focus
be effective in cleaning up site contamination This single-remedy approach (e.g excavation,thermal treatment) was sometimes effective for leaking Underground Storage Tank (UST) sites
Trang 21involving shallow soil contamination But it backfired on sites containing more complex geology,groundwater contamination, and certain contaminants of concern (C of Cs) UST sites withshallow soil contamination provided Contractors and Government ER Service Providers withmany early wins for accelerating site cleanup.
The Contractor project team single technology focus extended to a narrow focus on thephysical site cleanup, with a lack of consideration to developing the final report duringfield execution Contractors were narrowly focused on cleaning up the physical contamination,not developing data and documents that would be essential for a high quality final reportdeliverable Contractors were commonly not focused on exit strategies and site closeout, andthis extended to Government ER Service Provider RPMs Government ER Service Providerinitiatives to accelerate site cleanup focused on two things: (1) maximizing the amount of fundsspent on cleanup and (2) maximizing the number of Remedies-in-Place Generating multiplesite exit strategies and achieving site closeouts were not the goals
“Silver-Bullet” Technologies
Contractors and technology subcontractors pitched their “silver-bullet” innovative
technologies to Government ER Service Provider RPMs Technology capabilities werefrequently overstated in proposals, and project work plans assumed the selected technologywould achieve remedial action objectives Many Government ER Service Providers RemedialProject Managers (RPMs) started to become skeptical of embellished technology claimsbecause the norm was technology underperformance or failure
Poor Technical Document Quality
The sense of urgency to get to the field and accelerate site cleanup caused Contractors to rushthe development of project work plans Work plans were frequently sloppy and requiredextensive Government review They commonly had mis-spelt words, gaps in logic, poorformatting, and led to numerous Government and regulatory agency comments seekingclarification Many Government ER Service Providers Remedial Project Managers (RPMs)became irritated with Contractors and downgraded their award fee Many Contractors ProjectManagers were critical of the document quality “nit-picking” because they claimed theirproject teams did not need professional quality technical publications with perfect grammar toclean up sites Bear in mind that many Contractor project teams engaged in cleanup consisted ofnumerous construction and earthwork veterans who did not perceive the need for high qualityproject work plans To them, it did not matter if the project work plan contained incorrectcorrect regulatory terminology and acronyms – those things had no bearing on their sitecleanup needs
Trang 22Many Government ER Service Providers Remedial Project Managers (RPMs) and
regulatory agencies had very high document quality expectations that arose from the era
of gold-plated study documents Consequently, most Contractors, feeling the pain of
their award fee downgrades, began to hire away professional geologists, engineers, andchemists and Contractors engaged in studies They desperately needed to build a staff ofscientists and professionals who could write design-build project works plans and othertechnical documents
Bigger Is Better
The DoD ER push to accelerate site cleanup fed the Contractor desire for “bigness”
Bigger technology was better Bigger technology meant faster and cheaper site cleanup.Bigger meant more yellow-iron, bigger Soil Vapor Extraction Systems, and bigger thermaltreatment units It did not take long for everyone to realize that bigger was not better, andmeant a bigger bust when technologies underperformed Many erroneous technical
assumptions were routinely made regarding site conditions that decreased technologyeffectiveness
In the pursuit of accelerated cleanup, many Contractors constructed full-scale remedialaction systems that were overkill for the site, without any thought given to optimization(predated optimization concept) One of these large scale projects in 1996 involved ayoung Navy RPM in San Diego by the name of Mr Richard Mach Jr He was assigned tomanage a full-scale Soil Vapor Extraction project at an active Navy installation in SanDiego It was a huge SVE system and it was burning through his project budget quickly.His project performance evaluations had a recurring “technology optimization theme”,and he downgraded project performance evaluations for not recognizing and
implementing optimization opportunities in a timely manner He built on his RPM
experience and helped teams to develop the technical optimization guidelines for the Navy
Mr Mach went on to become a significant driver for technology optimization in the DoD ERindustry
DERP ER Programs Shifts Focus to “Site Closeout”
TheDefense Environmental Restoration Program, Annual Report to Congress (FY 1997) was the firstreport to establish a focus on “site closeout” The introduction conveys the shift: “In reporting on theDERP’s status in FY97, the focus is on the road to Site Closeout”
The report contains a section entitled, “The Road to Site Closeout”, which states,
After more than a decade of effort and billions of dollars of expenditures, the Defense
Department’s environmental cleanup program is moving with increasing rapidity toward
Trang 23Site Closeout at a majority of its installations and sites The initial focus of the program
was on finding the sites with problems (site identification), deciding how best to handle
cleanup at these sites (remedy selection), determining which sites to clean up first (risk-based prioritization), and beginning the cleanup process (remediation design and beginning con- struction) Today the Department’s progress can be measured by the number of Remedies in Place (RIP) and the number of sites categorized as Response Complete (RC), which indicate that sites are reaching the last milestones in the often lengthy cleanup process The phrase
“Road to Site Closeout” highlights DOD’s objective of completing the cleanup program.
Figure 1.4 shows the relationship of these milestones, and shows response complete and sitecloseout can take place at any time during the process
New DERP ER Emphasis on “Remedial Process Optimization”
Identifying and Implementing Expedited Remediation Approaches, introduced the concept ofRemedial Process Optimization It states:
DoD strives to maximize limited program resources by conducting environmental restoration activities in the most efficient and expedient manner possible One tool that has been extremely helpful in evaluating and improving site remediation processes so that maximum risk
reduction is achieved for each dollar spent is remedial process optimization Remedial
process optimization is a systematic, iterative process that assesses remediation efforts to
enhance technical effectiveness and reduce overall site cleanup costs This process evaluates remedial processes for overall system effectiveness, taking alternative remedial approaches and new technologies into consideration Remedial process optimization offers multiple
benefits, including the evaluation of remedial progress through data collection and
Remedy in Place Remedial Action
Construction
Start Milestone Complete
Remedial Action Operations
Response Complete
Long-Term Monitoring
Site Closeout
Figure 1.4 The relationship of these milestones.
Trang 24established cleanup goals; the acceleration of site transfer; reduced operation, monitoring, and maintenance costs; and superior protection of human health and the environment.
Remedial process optimization is cyclical in nature and is designed to ensure that cleanup goals are met fully and efficiently.
“Red and Unsustainable Remediation?”
Shortly after the turn of the century, DoD Component leaders started evaluating fundingallocation trends from 1998 to 2001 and became alarmed at the increasing percentage of DERP
ER funds consumed to simply sustain remedies in place, such as pump and treat The total cost
to operate and maintain installed remedies (i.e sustain remedies), combined with the total DoDComponent programme support cost, was rapidly increasing
For many installed remedies, The Road to Site Closeout had no end in sight If this trendcontinued, the DERP ER Program would become unsustainable – annual DERP funds for eachDoD Component will be consumed by Program Support combined with the open commitments(cost) to operate and maintain passive Remedies-in-Place
DoD Components Expedite Technology Optimization Policies
Program (DERP), in September 2001 Section 20 gave DoD components the requirement toestablish technology optimization policies It requires DoD Components to continuallyoptimize remedies Following issuiance of this document, leaders from each DoD Componentstarted developing their respective technology optimization policies and technical guidancedocuments
For example, the Navy issued a 1 October 2003 policy memo that stated the following:
As the Navy/Marine Corps have progressed through implementation of the Installation
Restoration (IR) Program and begun the Munitions Response (MR) Program, many sites
have advanced through the remedy evaluation, selection, design, and construction phases and are undergoing Remedial Action Operation (RAO) and Long Term Management
(LTMgt) This has shifted a growing proportion of the available Environmental Restoration Navy (ERN) and Base Realignment and Closure (BRAC) funds to these long-term site
cleanup commitments Continued monitoring of many of these remedies has indicated that remedies selected are not meeting cleanup objectives as planned Further evaluation of
specific sites has revealed several areas where optimization efforts could be applied to
ensure the most appropriate remedies are screened, evaluated, selected, designed, and
properly operated/maintained, and that options are available to modify systems to ensure cleanup objectives are met in a timely, cost effective manner These results prompted the need for further optimization direction Section 20 of the Management Guidance for Defense Environmental Restoration Program (DERP), September 2001, requires the Components to
Trang 25continually optimize remedies This policy outlines the Navy/Marine Corps efforts to be
conducted to ensure all remedies are continually optimized through evaluation of all
available data at each phase of the project.
The Navy Policy also contained a “Special Technical Issue”:
Since 1998, Navy, other DoD Components, and the Environmental Protection Agency
(EPA) have been conducting evaluations of the effectiveness of “pump and treat” systems
to address groundwater contamination Consensus of all parties is that pump and treat systems are rarely the optimal alternative for groundwater response actions Therefore, any plans
to install new pump and treat systems on Navy and Marine Corps installations requires
approval from Headquarters (HQ) at the Naval Facilities Engineering Command (NAVFAC) This requirement applies to all “pump and treat” systems (remedial and removal actions)
where groundwater is removed from the sub-surface by pumping or other means, treated
above ground in any way, and discharged in any way (i.e off site disposal, sewer systems, re-injected, etc.) In order to receive the NAVFAC HQ approval, the IR Manager shall forward
a summary of the site background, the conceptual site model (CSM), the remedial action
objectives, a listing of the technologies screened for the site, a summary of the alternatives analysis, and a statement of why “pump and treat” is the most appropriate technology to
be used at the site, including a life cycle cost analysis (net present value and total site cost) and exit strategy NAVFAC HQ will provide a written approval/dis-approval response to the
IR Manager based on review of this submittal.
DoD ER Components wanted RPMs and Contractors to adopt an “exit strategy” mentality.The new Government philosophy could be summed up as follows, “We value site closure and
Flexible Contractor technical approaches and the ability to articulate exit strategies becamethe common Contractor proposal win theme This influenced the RPM perception of bestvalue Contractor proposals, project work plans and regulatory documents evolved from ashort-term focus on achieving “Remedy in Place” to a flexible technical approach to achievesite closure The transition to “Performance-Based Multiple Award Contracts” with an emphasis
on optimization reinforced the importance of a flexible approach to managing project scope.The DoD Navy Component “Optimization Work Group”, led by Mr Richard Mach, drafted the
1 October 2003 Navy optimization policy and published the following optimization guidelinesthat can be downloaded for no cost on the Navy (NAVFAC) website:
Closeout Process (March 2006)
Trang 26Guidance for Optimizing Remedy Evaluation, Selection and Design was first published in April
2004 and was recently updated It was groundbreaking work that introduced numerousoptimization concepts and guidelines It described the “Treatment Train Concept”, andprovided examples of how exit strategies can be developed for each target treatment zone
It sensitized project teams to the economics of remediation It also introduced guidelines fordeveloping a “Flexible Record of Decision (ROD)”
New DoD ER Acquisition Strategy
The (2002 to Present) emphasis on technology optimization corresponded with a majorshift in DoD ER Component Acquisition Strategy The DoD Acquisition Strategy shiftstarted in 2002 CPAF contracts produced reasonable and consistent profits with negligible riskfor a few large Contractors Consequently, many smaller Contractors lobbied the U.S Congressthat the environmental restoration programme had become a welfare programme for largebusiness (it did not matter that most CPAF contracts required over 60% of the work to besubcontracted among small businesses) Congress, in turn, directed the DoD to spread theenvironmental restoration workload and dollars to more Contractors, with an emphasis on smallbusiness Contractors
DoD components responded by scaling back CPAF contracts They changed their acquisitionstrategy to involve more Small Business Contractors, increase competition, and createaggressive goals for using fixed price contracts The DoD Components emphasis shifted toPerformance-Based Contracting, as described in the Federal Acquisition Regulations, Part 37,Service Contracting Specifically, Subpart 37.6 pertains to Performance-Based Contracting.One very popular contract vehicle to emerge was the fixed price Performance-Based, MultipleAward Contract (PB-MAC) On PB-MACs, the Government starts with an open competitionamong Contractors for a “seat at the table” PB-MACs are competed as Unrestricted (LargeBusiness), or Small Business The objective is to hire three to six Contractors who will
compete with each other on a case by case basis for contract task orders (CTOs) (i.e projects)DoD components who were accustomed to working with three to five large Contractors andtheir funded “Program Management Offices (PMOs)” prior to 2002 were suddenly dealing with25–35 Contractors including many small businesses with no PMOs Proposal evaluationsbecame routine
PB-MAC Requests for Proposal (RFPs) feature a “performance based” statement of work, alsoknown as a Performance Work Statement (PWS) The PWS summarizes desired projectobjectives, important schedule milestones, deliverables, historical information and data.The PWS includes a table to specify performance standards, results, and metrics The PWSdeliberately avoids prescribing “how” the Contractor shall perform the work PB-MACsprovide competing Contractors with the freedom to formulate a flexible, design–build technical
Trang 27approach, explain the exit strategies, and “sell” the benefits within the results-orientedPWS framework The Contractor’s project quality control plan includes procedures fortracking and reporting performance and results relative to the PWS metrics.
Contract Task Order values range from 100 K to 30 million USD, with most in the 2–5 millionUSD range Total PB-MAC capacity is commonly 100 million USD Contractors are required
to bond the work Sometimes the selection criterion is best value In other cases it is low price.The DoD transition to PB-MACs provided Contractors with more flexibility on how toapproach proposals, technical approaches, work plans, staffing, and metrics on projects It alsoprovided Project Managers with more flexibility to make scope adjustments during projectexecution
Shift in Government and Contractor Quality Management
From the early days of the DERP ER Program, the DoD Components embraced the U.S.Army Corps of Engineers standard for Construction Quality Control The most fundamental
CQM Contractor QC referred to the Contractor Quality Control Representative Government
QA referred to the Government Quality Assurance Representative CQM referred to
Construction Quality Management PB-MACs place 100% CQM responsibility on the
CQM With this change, the Government is proclaiming: “We’re not going to exert any effortmaking sure your performance and results meet contract requirements – that’s your
responsibility” The Government QA role shifts to performance assessment
Green and Sustainable Remediation
(September 2010) to fuel the green and sustainable remediation movement On 10 August 2009,
Green and Sustainable Remediation Practices in the Defense Environmental RestorationProgram Each DoD ER Component Service Provider started developing GSR guidancedocuments and tools For example, the Air Force developed the Sustainable Remediation
Component representatives participate in industry initiatives such as the Sustainable
Remediation Forum (SURF) The Interstate Technology & Regulatory Council (ITRC)established a GSR Team ER Service Provider organizations commonly develop their ownguidelines, “brand” their tools just like corporations, and develop their own acronyms.Many organizations, including the U.S Federal Government and DoD Components, haveembraced GSR They are working hard to develop guidelines and tools for the ER industry
Trang 28In the future, GSR, like technology optimization, will be considered throughout the ER projectlife cycle to identify opportunities to minimize adverse environmental impacts (e.g greenhousegas emissions), natural resource consumption, energy usage, and maximize recycling Forexample, DoD ER Components and Contractors will implement the Sustainable Remediation
The most intriguing aspect of the global ER GSR initiative is the complete lack of awareness
framework for effectively implementing GSR on ER projects Many of these organizations,such as the U.S federal government, are currently implementing an ISO-14001 EMS [Refer toDefense Environmental Restoration Program Annual Report to Congress (FY2009), Chapter 2,Environmental Management Systems] According to the report:
facilities
facilities
Effective implementation of the ISO-14001 EMS prevents pollution and decreases operations
logical, and cost-effective way to implement GSR Going one step further: The DERP ERemphasis over the next decade will be annual site-specific life cycle analyses of installedremedies relative to performance objectives Performance objectives can range from
protectiveness to unrestricted site release The ISO-14001 EMS provides a consistent
framework and methodology for effectively implementing the life cycle analysis process,which can incorporate GSR screening As of this print, DoD Components do not intend toutilize an EMS to implement their installation restoration program
Contractor Environmental Project Team Challenges
Contractors, Project Managers, and their project teams now face several challenges caused byintensified competition and higher risk:
project objectives, desired results, and key schedule milestones Contractors propose theirtechnical approach to achieve the results, outcomes, and schedule Contractors areuncompensated for PMO key personnel (even though required by contract), proposaldevelopment, and face stiff price competition for awards
receive less than 1 month to evaluate most RFPs, understand site conditions, evaluatepotential technical remedies, identify risks, prepare proposals and cost estimates, and
Trang 29obtain approval from senior management to submit a proposal This time crunch also makes
it very difficult to obtain competitive bids from subcontractors
Managers and technical staff are expected to write proposals, obtain input from
subcontractors, prepare cost estimates, articulate the risk factors and countermeasures toupper management, and execute the awarded project on schedule and within budget
and engineers, specialty subcontractors, an increased emphasis on timely data evaluation,and the ability to expedite changes in a safe and controlled manner
anticipate, perform, and document scope adjustments during field execution
fewer project team staff; in turn, fewer staff have expanded responsibilities such as healthand safety and quality control
on subcontractors Many subcontractors do not pay close attention to the statement of work,lack expertise in quality control, and must be controlled
Customer QA Representative as “a second set of eyes” to make sure contract requirementsare met, field staff are adhering to project plans and procedures, nonconforming materialsare rejected, reports are reviewed, etc
provide early recognition and timely communication of issues including recommendedoptions Otherwise, they may be labelled as “reactive” by the customer
that contract performance and results meet requirements Otherwise, payments may bedelayed or invoices may be marked down
envision using collaborative project websites to manage their project tasks, deliverables,and records Now project teams routinely develop and use websites without assistance fromInformation Technology specialists This is a disruptive change to managers and
professionals who prefer collaboration by e-mail
challenges listed above, the Contractor Project Manager must run a safe project, and meetthe targeted (“as-bid”) profit margin Winning repeat business substantiates customersatisfaction
Trang 30These challenges reflect a maturing industry with stronger competition and higher risk.Environmental project teams are now tasked with a broader range of responsibilities with lessstaff As recent as 5 years ago, project teams had dedicated Superintendents, Project ControlsEngineers, Project Quality Control Representatives, Project Health and Safety Officers, andProject Accountants Most Project Managers would also claim they had more technical supportand more administrative assistants to help prepare and manage documents and records.Environmental Restoration Project Manager, Inc.
If you are an ER Company Inc employee who supports several Project Managers, and want toget a good laugh, ask a PM, “How are things going at (PM’s Last Name), Inc.” Most times youwill be greeted with a smile and laugh because that is how they usually feel They are 100%responsible and accountable for their project team success, and winning follow-up projects.Most PMs would rather have it this way PMs prevail by thinking and acting like small businessowners, and helping their customers meet project objectives If they are not thinking like smallbusiness owners, they need to be
Chapter topics selected for this book target ER Project Manager, Inc., and project teamprofessionals The Project Manager cannot do it all Their professional staff need to broadentheir skills For example, in baseball, a five-tool player is one who excels at the following:(1) hitting for average, (2) hitting for power, (3) base running skills and speed, (4) throwingability, and (5) fielding abilities Professional baseball players rarely excel at all five.Consequently, five-tool players are highly valued free agents The same applies for ERprofessionals A skill deficiency relative to any chapter topic will decrease your value to ERproject teams PM, Inc needs someone to provide support on each skill Why not you? Do notlimit your utilization opportunities and ER career to being a two- or three-tool player.Fewer tools cause lower labour utilization Lower labour utilization means your name will be
on the project or Company furlough list when times get tough Seize the opportunity to increaseyour value by broadening your skills because you never know when you might need to become
a free agent But if you do, you want your professional resume to appeal to the growingmarket of PM Inc.’s who are competing to attract and retain talented project team members.This book summarizes a series of best practices based on lessons learned that will help Contractorproject teams continuously improve competitiveness and performance on ER projects
Chapter Overviews
Chapter 2: Understand Your Government Client Business Model
Each Government Environmental Restoration (ER) Service Provider conducts business
differently, even within the same agency This chapter provides guidelines for profiling andunderstanding the Government ER Service Provider business model, which dictates
“How we conduct business” or “How Contractors are expected conduct business with us”.The Environmental Restoration (ER) Service Provider Business Model and cultural characteristics
Trang 31flow down into Contractor processes Contractor Project Managers and teams need to
understand the Government ER Service Provider business model in order to become betterconsultants Each Government Environmental Restoration (ER) Service Provider business modelinfluences how Contractor project teams tailor and implement best practices described inChapters 3 through 10
Chapter 3: Implement a Flexible Environmental Quality Management System
ER Contractors must establish and implement a flexible environmental quality managementsystem (EQMS) to adapt to specific Government ER contract types and special initiatives such
as performance-based contracts The Company quality manual should be based on ISO-14001,Environmental Management Systems (EMS), but should be referred to as the Company
“EQMS” in proposals and literature ISO-14001 provides an ideal framework for effectivelyimplementing performance-based contracts, and adapting to evolving Government ERprogramme contract requirements
Quality plans for performance-based contracts must integrate into the Government’s
performance assessment and evaluation cycle Contractor project teams implement workprocesses, Functional Inspection Plans, process improvements and a Monthly QC Reportprocess that demonstrates Performance Work Statement (PWS) requirements and performancestandards are being met Contractors are responsible for providing the Government withdefensible objective evidence to substantiate higher performance evaluations and award ofcontract incentives
Chapter 4: Develop and Utilize User-Friendly Project Websites
In just 15 years, from 1995 to 2010, information technology has completely transformedthe way the Government and ER project teams communicate, develop, and manage
information E-mail was a breakthrough in collaboration Now Microsoft SharePoint projectwebsites can be rented for as little as 10 USD/month from professional web-hosting companies.Many Project Managers with extensive website experience view a small number of project
Project Correspondence Log for managing contractual communication, are described in thischapter However, the transition to paperless web collaboration is counterproductive toproject teams in the field Their productivity is maximized with a well-organized set oftraditional three ring-binders
Chapter 5: Develop Superior Proposals
The Government transition to Performance-Based Multiple Award Contracts (PB-MACs) hascaused proposal development to become a routine Project Manager and team activity.Contractors mobilize proposal development professionals and expertise to win the Basic
ER Program Contract Then Project Managers and teams are expected to develop superior
Trang 32project proposals and win projects Many have not received practical training on pre-proposalcapture planning, discriminator development, and proposal writing They might not recognizethe importance of understanding how Government Technical Evaluation Boards scoreproposals Unfortunately, the challenge to develop superior proposals is compounded whenthe Government squeezes Contractors with a 3- to 4-week proposal due date This chapterprovides Project Managers and teams with practical guidelines for developing superiorproposals and includes recommendations for Governments ER Services Providers who seek
to obtain better value and lower Contractor prices
Chapter 6: Develop Superior Project Work Plans
Technical document quality was a major Contractor discriminator opportunity in the 1990s.And it remains near the top of Government ER Service Provider wish-lists today Interviewyour Government ER Service Provider Remedial Project Managers (RPMs) and they willconfirm this fact While Contractors continually strive to differentiate their value proposition
on many proposal factors that have become neutralized in the maturing competitive market,many continue to underestimate the competitive advantage opportunity that exists for technicaldocument quality Your company cannot rise above the competition without a leadershipcommitment, mission, and plan to become the undisputed leader in technical document quality.The chapter provides programme and project teams with guidelines to develop superior projectwork plans and technical documents On most ER projects, technical document quality makesthe first and last impression on your Government ER RPM
Chapter 7: Implement More Rigorous Scope Management Tools
Government ER RPMs value scope flexibility on all ER projects including fixed price,without triggering modifications that increase the total contract value But if ContractorProject Managers and teams struggle to effectively manage scope, their projects willexperience substantial cost overruns The competitive challenge to Project Managers is clear:learn how to maximize flexibility without losing control This must be done at each ERproject phase: proposals, technical approaches, work plans, and field execution Flexibleproject scope management requires Contractor ER programmes and project teams toimplement better scope communication tools and processes to manage scope Tools such asthe project correspondence log, basewide risk register, project risk register, scope register,scope coordination and mutual understanding meeting, and scope variance communicationlog enable proactive scope management and customer satisfaction without loss of control.Chapter 8: Effectively Control Field Work
This chapter describes enhancements to an ER-proven model called the “three phases ofcontrol” for effectively controlling field work The team approach described in this chapter is
Trang 33which has been used for several decades by the DoD ER Components (this standard can bedownloaded at no cost from the internet) Leaner project teams must implement a streamlinedapproach that engages the multiple team members The Project QC Manager and ProjectManager designate a “Task Leader/QC/Safety Specialist” for each task on the projectschedule This includes high risk support tasks that involve safety, permits, and regulatorycompliance Each task, termed as a “Definable Feature of Work,” represents a three-phaseinspection unit Project managers can break tasks into smaller DFW control units if justified
by task risk and complexity Supervisors can use three phases of control for any task.Chapter 9: Implement Cause Analysis to Generate Solutions
Government organizations can achieve better prices and better value environmentalservices), is an enabling technique for generating solution opportunities in an industry whereflexibility is valued and failures are commonplace The value of cause analysis stands farabove any other process improvement tool Government ER Service Provider RPMs areinherently skeptical of Contractor claims They value risk management, flexibility, andmultiple solution options – all enabled by effective cause analysis Cause analysis willcontinue to be indispensable for major project problems that jeopardize the contract.However, leaders who limit the application to a crisis, or erroneously view cause analysis as
an exhaustive exercise, are failing to capitalize on a major opportunity to improve
performance Cause analysis training offers the best return on investment for any training youcan provide ER Project Managers and teams
Chapter 10: Design User-Friendly Work Processes for Project Teams
User-friendly work processes achieve the following objectives: (1) eliminate narrativeverbiage, (2) maximize the use of visuals, and (3) break the procedure into components toenable flexibility and process improvement Project teams are busy They do not have time
to read procedural verbiage This chapter provides guidelines for designing user-friendlyprocesses and checklists that cause project teams to think Thinking project teams succeed onprojects Doer project teams become complacent, mechanistic, and reactive to problems onprojects Processes must be clearly visible to project team members, not buried within theexcess verbiage of procedure narratives
Trang 34Understand Your Government Client
Business Model
“Government Client Business Model” This phrase sounds like an oxymoron If your driven” mission is to help your Government Environmental Service Provider clients succeed,you must strive to define, understand, and effectively implement their respective business models.Your service is an extension of their programme policies, goals, installation cleanup plans,and site-specific cleanup objectives But one basic obstacle complicates your learning curve:Most government clients do not acknowledge they have a business model Consequently, itremains a nebulous mystery that is subject to interpretation Contractor best practices cannotachieve their potential without developing and implementing flexible systems and processes thatcan be tailored to each Government Environmental Service Provider’s business model
“customer-This chapter provides guidelines on how to piece-together (i.e profile) a GovernmentEnvironmental Service Provider Business Model Consider constructing a business model foreach targeted Government Environmental Service Provider client Each DoD EnvironmentalRestoration (ER) Service Provider organization implements a unique business model, andevolves their own approach for doing business Although each DoD Environmental Restoration(ER) Service Provider organization shares common higher level DoD values and goals(e.g efficient, protective, and cost-effective site closeouts), they are not required or expected toagree on “how to” specifics For example, the Army, Navy, and Air Force might not share acommon perspective and approach to risk-based site cleanups, scoping site cleanups tomatch land use, and the implementation of life-cycle cost analysis concepts Government RFP’sfor ER contracts assume competing contractors are familiar with how they do business.Business Model Elements
The Government ER Service Provider Business Model is the foundation of Contractorknowledge Multiple Base Cleanup Team Cultures are the next higher level The top level isSite-Specific Intelligence (for individual sites on the base) Collectively, these are shown in
seek an advanced understanding of these elements
For example, Chapter 5, Developing Superior Proposals, describes the importance of
understanding the Base Cleanup Team (BCT) Culture and gathering site-specific intelligence.Base Cleanup Teams operate within the contracting and administrative business model of their
Best Practices for Environmental Project Teams DOI: 10.1016/B978-0-444-53721-8.00002-6
# 2011 Elsevier B.V All rights reserved.
23
Trang 35parent organization (i.e Government Environmental Service Provider organization).
hopes, fears, and biases
Several top-performing Government Environmental Service Provider Remedial Project Managers(RPMs) operate like successful small business owners who effectively implement the businessmodel They excel at each level Some deliberately approach their projects as if they (as individualland owners) are the Potential Responsible Party for the site They give Contractor project teamsthe impression that every site cleanup dollar being spent is from their own bank account.Contractor Project Manager site-specific intelligence gathering will become increasinglyimportant as Government Environmental Service Provider RPMs increase their use of life-cycleanalysis concepts for scoping, assessing, and reporting sites The importance of conducting life-cycle cost analysis increases once “protectiveness” of human health and the environment isachieved (e.g DoD “Response Complete”) Simply stated, the site is no longer a threat
Response Complete and Site Closeout protective of the limited funding available, or is the complete Site Closeout cost-prohibitive? It is never too early for Government EnvironmentalService Provider RPMs and Contractors Project Managers to begin life-cycle analysis andperiodically assess the economic feasibility of trying to achieve future land use objectives.Constructing the Government ER Service Provider Business ModelEach country and Government ER Service Provider organization develops and implementstheir unique business model, which must be understood by Contractor project teams Forexample, the following 8 business model characteristics apply to the U.S DoD components:
cost-to-Figure 2.1 Business Model Elements.
Trang 361 Federal Requirements that establish the basis for Environmental Restoration Program.
the driving force behind the programme, and flow down through component organizations
metrics, (which do not mirror the regulatory process);
4 The U.S Department of Defense, Component-Specific, Environmental Restoration (ER)Service Provider Programme Progress Reports, and Execution Plans;
5 The U.S Department of Defense DoD, Component-Specific, Environmental Restoration(ER) Service Provider guidelines for achieving site closeout;
6 The U.S DoD, Component-Specific, work groups and programme initiatives;
7 The U.S DoD, Component-Specific, management information systems (e.g intranet),software, databases, and processes for conducting business;
8 The U.S DoD, Component-Specific, acquisition strategy and contract vehicle types for
Performance Based Multiple Award Contracts) This also includes acquisition plan andapproach for awarding contracts to Small Businesses
This is not an all-encompassing list Any business model characteristic, which defines
“How we conduct business” or “How Contractors are expected conduct business with us”,
is part of the business model
The eight business model characteristics listed above will be summarized for the Navy (NavalFacilities Engineering Command) They influence how the Navy conducts business, and whatthey expect from Contractors Several basic business model features are not covered in thisexample, such as their organization chart, the role of specialty support organizations forprojects involving radiological and munitions contamination (e.g., Navy Radiological AffairsSupport Office; Naval Sea Systems Command, Naval Ordnance Safety and Security Activity),their internal budgeting cycle, important rules dictating how they classify and obligate contractfunds, etc This business model example will help you develop your own
NAVFAC Environmental Restoration (ER) Service Provider
Business Model
Federal Requirements that Establish Basis for Environmental Restoration ProgrammeDoD conducts cleanup in accordance with the following federal requirements:
Response, Compensation, and Liability Act (CERCLA)
Trang 37Source: United States Defense Environmental Program Report to Congress, Fiscal Year 2009,Prepared by the Office of Under Secretary of Defense for Acquisition, Technology andLogistics (April 2010).
Programme policies
DoD developed policies and guidance to meet the above federal requirements, including:
Eligibility”
Defense Environmental Restoration Program (DERP)”
Source: United States Defense Environmental Program Report to Congress, Fiscal Year 2009,Prepared by the Office of Under Secretary of Defense for Acquisition, Technology andLogistics (April 2010)
The NAVFAC website currently organizes 14 files for Department of Defense Policy andGuidance and 38 files for Department of the Navy (DoN) Policy and Guidance
Navy Environmental Restoration Process and Progress
Reporting Metrics
Each Contractor should understand the site Environmental Restoration Process path andclient progress reporting metrics that apply to the site they are targeting prior to the RFP This isimportant because not all phases or milestones are necessary for each project, and site closeoutcan be achieved at multiple stages throughout the project life cycle
2010), describes the major steps in the Navy ER programme, which encompasses both theInstallation Restoration and Munitions Response programmes In addition to RCRA andCERCLA frameworks, several Department of Navy (DoN) installations conduct remediationprojects under state-led Underground Storage Tank (UST) cleanup programmes State USTprogrammes guide cleanup at most petroleum hydrocarbon-contaminated sites UST
programmes are delegated to the state level, as part of RCRA, and may incorporate
requirements that are more stringent than Federal UST regulation Although RCRA, UST, anda
Throughout FY 2009, 1 October 2008 to 30 September 2009, DoD continued to update the DERP Manual, which will supersede the 2001 Management Guidance for the DERP.
Trang 38Table 2.1 Major Steps in the Navy ER Programme
Preliminary Assessment (PA) The PA is a brief assessment that uses available historic
information to determine the probability of and possible locations of potentially contaminated areas.
physical inspection of potential sites and, depending
on site type, would include soil, surface water, sediment and/or groundwater sampling.
characterizing the site (including nature and extent of contamination), determining the regulatory requirements, and conducting a baseline risk assessment for human health and the environment.
the FS to identify and analyze the range of remedial actionoptions available at a givensite RPMscanreferto several United States Environmental Protection Agency (U.S EPA) guidance documents associated with preparation of an FS, such as Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA, Interim Final (U.S EPA, 1988): http://www.epa.gov/ superfund/policy/remedy/sfremedy/rifs/overview.htm Engineering Evaluation/Cost Analysis (EE/CA) Non-time critical removal actions and interim
remedial measures require completion of a less comprehensive feasibility review called an EE/CA More information can be found in the U.S EPA Guidance on Conducting Non-Time Critical Removal Actions under CERCLA-OSWER Publication 9360.0-32 (1993a).
background information on the site, the preferred remedial approach, and the rationale behind its selection The ROD is completed after a Proposed Plan (PP) has been drafted and released to inform the public and obtain comments on the preferred remedial approach The U.S EPA Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents provides more detailed information on the recommended outlines and content for PPs, RODs, Explanation of Significant Differences (ESD), and ROD Amendments (U.S EPA, 1998).
An Action Memorandum is the abbreviated form of a decision document for removal actions, except that the ActionMemorandumisonlyrequiredtobesignedbythe installation Commanding Officer, and not by the
regulatory agencies.
Continued
Trang 39Table 2.1 Major Steps in the Navy ER Programme—Cont’d
An improved ROD is a traditional ROD that provides the full rationale for remedy decision in a concise document through the use of streamlined text, figures, and tables with appropriate references to supporting documentation in the administrative record (AR) The improved ROD must comply with CERCLA and the NCP and follow U.S EPA guidance The distinguishing characteristics of an improved ROD are a consolidated outline, detailed references to
AR documents that substantiate the information presented, and concise text with maximum use of tables and figures, including a graphic CSM, to summarize key information in formats that are easily interpreted by most readers More information on improved RODs is available on the Navy improved ROD Web portal at: http://www.ert2.org/
t2RODPortal/id¼home.
which includes preparation of technical work plans,
drawings, and specifications.
Remedial Action Construction (RA-C) RA-C is the part of the remedial action phase in which
a construction Contractor cleans up the site or builds and installs a remediation system, and demonstrates that the system is functioning as designed.
which indicates that the remedial action has been successfully constructed or implemented, and has been demonstrated to be functioning as designed Remedial Action Operations (RA-O) RA-O is the part of the remedial action phase in which
the ongoing cleanup work takes place, including O&M support and ongoing monitoring to ensure that the system is operating properly and successfully Some sites are cleaned up during the RA-C phase (e.g excavation), and therefore may not require RA-O.
met and the site no longer represents an unacceptable risk to human health and the environment.
following RC to ensure that conditions at the site continue to be protective of human health and the environment This could include additional monitoring, land use controls (LUCs), and 5-year reviews.
use, unlimited exposure (UUUE) and there is no expectation of further funds to be expended at a site.
Trang 40CERCLA processes for site remediation are similar, the terminologies for each project phaseare different, as shown in Table 2.2 These are not necessarily linear steps–not all phases ormilestones are needed for every project The Navy implements site cleanup metrics based onsite cleanup status.
The Navy uses a “NORM/Cost-to-Complete Database” to prioritize sites and track cleanupprogress Since NORM is a database, it could be included in the business model category fordatabases However, NORM is an internal Navy database and Contractors do not uploadinformation to NORM
Navy Programme Progress Reports and Execution Plans
The Navy publishes programme plans that provide valuable insights into their ER programme,
Transfer Five-Year Program Plan for Environmental Restoration (2010 to 2014) Additionally,the Navy Base Cleanup Teams implement installation-specific execution plans
Navy Guidelines for Achieving Site Closeout
Closeout Process (March 2006) The purpose of this guide is to outline a consistent approachfor Navy Remedial Project Managers (RPMs) to follow in recognizing and documentingspecific milestones for achieving site closeout This guide identifies the particular documentsthat are needed at appropriate stages of the closeout process to record agreements andconcurrence of regulators This guidance addresses closeout documentation requirements forvaried regulatory frameworks, the Comprehensive Environmental Response, Compensation,and Liability Act (CERCLA), the Resource Conservation and Recovery Act (RCRA), and theUnderground Storage Tanks (UST) Programmes Samples of concurrence letters and Record ofDecision (ROD) language are provided in the appendices to assist RPMs in preparing
Table 2.2 RCRA, UST, and CERCLA Processes for Remediation of Contaminated Sites
Inspection (PA/SI)
Corrective Measures