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Pages 16-31

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From page 16...
... confirm, clarify, and expand DOE Order 413.3B to establish its applicability to all capital asset projects (not just construction and major instruments and equipment and certain cleanup projects) and all Office of Environmental Management projects, whether major systems projects or work carried out by a management and operating (M&O)
From page 17...
... Recommendation 5-3: The Department of Energy's Office of Envi ronmental Management should explicitly include the percentage of cost overrun or underrun in the project success metrics dashboard, rather than the current "green/yellow/red" metric, to bring more transparency to cost performance. Contract Structures Recommendation 6-1: The Department of Energy's Office of Envi ronmental Management (DOE-EM)
From page 18...
... DOE-EM should apply to such task orders the same management oversight as currently required for major systems projects exceeding $750 million in total cost. Contract Management Metrics Recommendation 7-1: To increase transparency in contractor per formance evaluation, the committee recommends that the Depart ment of Energy's Office of Environmental Management should ensure that the contracts it issues for cleanup work (1)
From page 19...
... Completion contracts were successfully used by DOE-EM at Rocky Flats and Fernald. DOE Order 413.3B: Program and Project Management for the Acquisition of Capital Assets (DOE, 2018)
From page 20...
... Program Management Improvement Accountability Act (PMIAA) : Public Law 114-264, enacted in 2016, to establish standards, policies, and guidelines for program and project management in executive agencies of the federal government.
From page 21...
... to Assess DOE-EM's [Department of Energy's Office of Environmental Manage ment's] program and project management practices benchmarked against DOE 413.3B and other practices used elsewhere for project planning and acquisition, technology insertion, controls, review, reporting, contract management, and other management activities.
From page 22...
... • The contract cost ceilings imply annual funding levels that are signifi cantly higher than historical experience, resulting in inefficiencies in contract execution if higher annual funding levels are not achieved. • Task order scopes of work are established after contract award, limiting incentives for technology and business model innovations in incumbent contractor proposals.
From page 23...
... was the initial vision for a performance-based contracting approach that incentivizes contractor execution and completion of work with clearly established performance expectations. This vision was substantially achieved in the completion contracts for cleanups of the Rocky Flats and Fernald sites, which began in the early 2000s.
From page 24...
... : $10 billion $1 billion Central Plateau Cleanup Companyc Savannah Savannah River Mission Completion $21 billion $2.1 billion River (IMCC) , LLCd Oak Ridge Oak Ridge Reservation Cleanup Contract $8.3 $830 million (awarded 10/26/21)
From page 25...
... defined as the specified situation, including accomplishment of completion criteria, for an environmental cleanup activity at the end of the task order period of performance (POP) ."b $500 million See previous No clear end state identified; any end state under the row Richland Operations Office Hanford Life-cycle Baseline through 2059 permitted.
From page 26...
... Finding A-1 identifies several problems with the ESCM as it is currently being implemented by DOE-EM: • The ESCM does not require that cleanup end states be defined for the full contract, as contrasted with the completion contracts that led to the successful cleanups of the Rocky Flats and Fernald sites. Although final cleanup end states at sites are generally well understood and embodied in estimates of total liability,3 meaningful program plans with well-defined intermediate end states are lacking.
From page 27...
... . • The 10-year contract lengths, with possible extensions, locks DOE EM into particular contractors and allows them to play a central role in defining task orders post-award, thereby limiting opportunities for competition, inclusion of new entrants into the DOE-EM contractor community, and injection of new ideas into the cleanup program.
From page 28...
... DOE-EM provided no documentation to the com mittee as to which of the six factors were used as the basis for the EM determination, nor was the committee able to obtain specific documenta tion from its virtual site visits on any individual end-state contract. • The contract cost ceilings are set at levels significantly higher than current annual funding levels, providing no effective cost control or accountability, and possibly leading to inefficiencies in contract execution if annual funding levels do not keep pace with future cost adjustments.  The cost ceilings for IDIQ contracts awarded to date are approximately $98 billion, or $9.8 billion per year on average over their 10-year draw periods (see Table 3.1, columns 3 and 4)
From page 29...
... • The existence of multiple task orders poses increased demands on DOE contract managers to ensure program and project effectiveness. The committee observed varying degrees of certification and training of DOE-EM staff in project management and end state.
From page 30...
... should work with the Office of Environmental Management, the Environmental Protection Agency, and state regulators, as appro priate, to incorporate procedural requirements for compliance with the Comprehensive Environmental Response, Compensa tion, and Liability Act (CERCLA) into the DOE Order 413.3B process, rather than exempt CERCLA projects from the order.
From page 31...
... Order 413.3B is not being used to manage DOE-EM cleanup projects conducted under CERCLA because many of its steps are duplicative of the CERCLA process, particularly in remedy selection. However, the CERCLA process does not contain the strong project management tools found in Order 413.3B.


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