chap2 project management

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Chapter2. PmiactManagemen

2.1 Introduction

Managing a remedial design (RD) or a remedial

action (ItA) presentsa number of challenges to theRemedial Project Manager (RPM). While RD/RAprojects are similar to other design and constructionprojects in many respects, there are uniquechallenges that RPMs face due to the sensitizedregulatory environment under which theseprojectsare conducted. For example, managing an RD/R.Aproject under the Comprehensive EnvironmentalResponse, Compensation, and Liability Act(CERCLA), as amended by the SuperfundAmendments and Reauthorization Act (SARA),requires that the RPM balance the sometimes

conflicting objectives and needs of individuals andorganizations whose cooperation is required forsuccessfulproject completion. This chapterprovidesthe RPM with the dafmition of project managementand covers the skills required of and the activitiesperformed by a successfulproject manager, qualityprinciples to be applied to projects.and other generalresponsibilities. The RPM should be familiar withthe project management concepts presented in thischapter and should periodically evaluate his or hermanagement approach for effectively directing anRDoranRA.

2.2 Deflnltionof ProjectManagement

Project management is the process of creating,monitoring, and controlling the scope of work,schedule, and budget of an RD/RA project. Theproject manager creates and manages the projectteam, which is composedof all project participants.The RPM as project manager actsas the focal pointof communications and coordinates project teamefforts, ensuring that project participants worktogether to accomplish the RD/RA project. The

project manage* maintains aclear vision of the tinalobjective-successful completion of the RDiRAproject on time and within the budget-whilecoordinating the individuals, organizations,technology, money, equipment, time, and otherresources to bring it about.

22.1 scopeof work

The RDRA scope of work must be based on the

Record of Decision (ROD), which defines theselected remedy to be applied at the site. The

elements of the ROD are contained within thefollowing documents:

l Work assignments(WAS) issuedto the EPAcontractor for Federal/EPA-managed sites

l Interagency agreements(IAGa) for Federal!United StatesArmy Corps of Engineers(USACE)-managed sites

l Cooperative agreements((X.5) for State-leadsites

l Consent decrees(CDs) or unilateraladmiiistrative orders (UAOs) forenforcement-lead sites

As the focus of the RLNh% Handbook is Federal-bad sites,CAs. CDs, and UAGs are not discussedin detail.

2.22 ProjectBudget,Funding,andcosts

Project budget, funding, and costsfor Federal- andstate-mad sites are maintained and tracked in theComprehensive Environmental Response,

Compensation, and Liability Information System(CERCLIS). One of the RPM’s most importantfunctions is updating RD/RA budget information inCERCLIS as the project progresses.

2.2.3 RDmAschedule

The project schedule, developed and managed bythe RPM, is also trackedin CERCLIS. It is specified

in the WA, LAG, CA, CD, or UAO, depending onthe site-lead status. Scheduling is necessary toanticipate when project resources or participationby others will be needed. The RPh4 updates the

scheduleas the RDfRA project progresses.

2.24 ProjectTeam

Creating and managing an RDiRA project teamfromall the participants in an RD/RA project is achallenge. The RPM must rely on his or her abilityto communicate among, direct, and coordinate



project participants. The RPM should usethe projectmanagement plan, the Technical Review Team(TRT), a communications strategy,and other toolsat his or her disposal to accomplish this task (seesections3.2,3.4, and 3.5).

2.3 Skillsofa SuccessfulProjectManager

Successfully managing an RDiRA project requiresthe RPM to blend a number of skil ls. Four of themost important, as listed in Figure 2-1, areknowledge of project management principles,competency asa manager in a project environment,leadership, and technical competence.

Skillsof a SuccessfulProjectManager

l Knowledge principlesf projectmanagementl Competencysa managern8 projectenvironmentl Leadershipl Technicalompatence

2.3.1 Knowledgeof ProjeefManagementPrinciples

Each RPM should understand basic projectmanagementprinciples and the application of theseprinciples for the successful completion of an RD/RA project. Technical competence alone is

insufficient becausea large portion of the RPM’sjob is comprised of non-technical components. Theproject manager must perform his or hermanagement functions with a foundation of basicproject management principles, supplemented by acommon-sense approach based on experience andeffective use of scheduling and budgeting systems.

23.2 Competencya8 Managern 8 ProjectEnvironment

A successful RPM exhibits certain characteristics,such as having a concern about quality and

performance, leadershipability, anticipating possibleproject constraints, staffing the project with qualitypeople, communicating frequently and effectively,having effective work systems,documenting theproject decision-making process, delegatingauthority when possible,being enthusiastic,andbemgsensitive to interpersonal and interorganizationalrelationships.

23.3 Leademhip

The RPM must lead, motivate, and inspire projectpersonnel to give their best efforts to the project.Completing an RD or RA brings peopletogether whodo not routinely work together. The RPM must

develop a project team to perform satisfactorily; anRPM’s personalattributes are asimportant asprojectmanagement systemsand procedures for this skil l.Leadership includes setting a pmject’s direction,establishing a vision, and developing andimplementing strategiesto achieve theproject goals.

2.3.4 TechnIcalCompetence

Ideally, tire RPM should be competentin adisciplinesuitable to the pmject. This allows the RPM to feelcomfortable with, and contribute to, the highlytechnical aspectsof the RD/RA and enhance his or

her ability to communicateeffectively with technicalparticipants in the project. An RPM familiar withthe technical aspectsof a project is better equippedto make decisions regarding the project scope,schedule,and budget issues,thus reinforcing his orher leadership position and gaining respect fromproject teemmembers. RPMs lacking the applicabletechnical abilities for their pmjects should selectothers with theseskills to assistin RD/RA activities.One of the besttraining methodsfor aninexperiencedRPM is to seek an apprentice relationship with anexperiend RPM, particularly before assumingfirsttime responsibility for an RDRA.

2.4 ProjectManagement

This se&m presentsapproachesto routine activitiesfor monitoring and managing RD/RA projects.Thesemethozisareextremely imp&ant in producinga successftdproject andhave theii roots in traditionalproject management.

Effective managementat the onsetof and throughouta project minimizes the obstacles that develop asthe project pmgresses. During initial project stages,

it is easier to effect change and to take correctiveaction. Changes during later project stagesusuallytake significantly more effort to achieve, cost more,and extend tlte schedule.

24d MoniforingheRDIRA

The RPM monitors actual site progress, adherenceto the project schedule, and budget and work



performance throughout the project, using a numberof techniques at hi or her disposal.

site Rogreas

The primary method for gauging site progress is tocompare actualevents with the scheduleand budget

developed in the planning phase; this isaccomplished by holding review meetings inconjunction with obtaining regular status reports.Both USACE and EPA contractors should producemonthly progress reports for RPM use. Morefrequent reports may be needed during RAconstruction (i.e., the RA statementof work [SOWJcould be written to require we&y reports). TheAlternative Remedial Contractiug Strategy(ARCS)/Response Action Contract (RAC) contractors arerequired by contract to provide specific types ofprogress reports that the RPM usesto compare the

actual scheduleand budget with the planned targets.To facilitate this comparison, the regular progressreports must:

l lkmmine the status and progress of each tasktowards its objective

l Report progress for the current period andestimateprogress for the succeedingperiod

l Report expenditures for the cm-rentperiod andestimateexpenditures for the succeedingperiod

l Review total expenditures

- Review the overall schedule and budget status

* identify issuesaffecting work progress,especially ones that may causedelay ornecessitateadditional funding

Schedule and Budgot

Monitoring and reporting of project s&ted&s areconducted using the techniques discussedin section3.8. The RPM usesthis information in the short-term to ensurethat critical milestonessuch asdesignreviews are met. These techniquesalso are usedfor

long-term project management decisions to avoiddelays that could at&t the schedule and budget.

Budget reports are monitored by the RPM to ensurethat a particular activity is being accomplishedaccording to its overall schedule and within thebudget ceiling, to ascertain that funding is spent

Chapter 2. Project Management

appropriately, and to obtain cost information forinvoice approval. The RPM also reviews budgetreports to assess the underutilization oroverutilization of funds and labor hours (burn rate)as compared to the expected burn rate.

Work PerformanceIn addition to routine monitoring of tire scheduleandbudget, the RPM evaluates work performance.Where deficiencies are noted, the RPM must beproactive and correct the deficiencies as soon aspossible. Early corrections allow a project to getback on course without additional expenditures andscheduledelays.

An RPM may receive a seemingly overwhelmingnumber of submittals (deliverables) becauseof hisor her monitoring function. A register, like the one

inAppendixB,canbeusedbytbcRPMssavaluabletool to track submittals,due dates,and required EPAaction. The RPM should decide which submittalshe or she will review and which submittals theTechnical Review ‘Tbam(seesection3.4) will review.

Implementation of effective quality assuranceandquality control (QAQC) activities to support RD/RA work is critical to work performance. The RPMis responsible for planning, implementing, andassessing the effectiveness of required andappropriate QA/QC activities thatsupport all phasesof the RD/RA process.Part C of the ANSVASQC

guidelines should be used as the basis for QA/QCfor RDBA projects.

ANSltASQC E4-1994, YSpecifiGcrfim and

Guidslifes fw Quality Sy&ms for

Environmental Data Coi&etion andEnvironmentd Teclzndog.vPrograms? Part C,provfdos the?minimum qu* systemsrequirements for f&e design consibdon, and

opcrcstion of teclmology used for ItDllus.

Although a project manager is held accountable forall aspectsof a project, a Superfimd RPM seldomhasthe authority or the control of all external factorsto ensure that a project proceeds according to plan.Thus, the RPM must develop a proactive approachto project management.

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RDiRAHandbook

For example, routine progress meetings help theRPM identify potential deviations from the projectstrategy. RPM response to a particular projectmanagement issuevaries depending on the problemand its immediacy-some deviations will be long-term trendsrather thanimmediate events. Deviationsfrom project strategy are avoided or controlled byinitiating preventive or corrective actions. Theproactive approachemphasizesanticipating potentialproblems and developing preemptive solutions,devising work-around strategieswhen problems doarise, and modifying the project with minimumdisruptions to handle surprise situations thatinevitably arise.

AntldpatocyAotlons

Anticipatory actions are preventive strategies foravoiding potential schedule ~disruptlons. Possible

actions include:

Requesting USACR assistancein EPAconIractor oversight

Maintaining strict submittal schedules

Increasing diit observation of office or fieldactivities

Maintaining awarenessof upcoming projectmilestones and associatedEPA reviews

Identification and resolution of propertyaccessissues

Early and continued interaction with thec0mmuni1y

Early stateinvolvement

Work*AroundS&te@

Work-around strategies respond to negativedeviations (usually in schedule,budget, or personnelresources) to accommodate changes and mittimizethe effects on overall completion of the project.Examples include:

l Streamliming requirements for work products

to avoid repetition of data in multipledeliverables

l Conducting in-progress reviews to eliminateinterim deliverable requirements

Modificationso Pfo]odStmtegy

Modifications sre used to accommodatedeviationsonly asa lastresort. Mcditications alter the projectbudget, schedule, or scopeand may require:

l Additional funding (ii available)

l ROD changes

l Superfund statecontract (SSC) changes

This section provides an overview of the RPM’sresponsibilities during the performance of the RD1RA. As a professional project manager responsiblefor the successful completion of a technicallycomplex, multi-million ,dollar design and

conmuction project, the RPM has an instrumentalmle in tbeplanning, execution, control, and closeoutof the RIYRA. As such,the RPM is a guardian ofthe taxpayer’s money, imbued with upholdiig thepublic trust In executing a ROD as promised.

To carry out his or herrusponsibilities, theRPM mustoversee the successful completion of the RLVRA.regardless of lead, and ensure that the completedremedy meets all goals and objectives described inthe ROD. The RPM’s involvemeut iu ensuring thatthe objectives and goals are achieved variesdepending on the designated lead agency or party.

In attempting to achieve the end results of the RA,the RPM should manage the big pi&ire and notmicro-manage all aspectsof the project. Micro-management can result in the RPM becomingoverwhelmed as the project progresses. The RPMmust useappropriate teammembers to help managethe RD/RA and delegate responsibility to thoseindividuals or organizations so that he or she caneffectively manage the entire project.

Specific details on RPM responsibilities arepresentedthroughout Chapters 3.4, and 5.

Flgure 2-2 lists the RPM’s general responsibilitiesduring each of the RD/RA phases. RPMresponsibilities can be divided into the followingcategories, each described below, which provide a



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Chapter 2. Projeci Managawt

cverall

RDIRA Plannlng

RWRAExecution

RDmA Closeout

RemedlelProjectManagementResponslbilltbs

- Ensures completed remedy meets all goals and cbjectiw fnthe ROD

* Focuses on Iha overafl management (%Ig picture’) versus micm-mana@emanlof RDiRA

+ Develops project managementplan

* Organizes TechnicalReview Team

* Establishes oommunications strategy

* Understands requiremants and pfwadures of EPA supfxxf contracbr

* Prepares SOW, Ma&k+ bu@evindepsadant gwemmant cost estimate

- Revises budge4and schedula basad on w&w of he cpn&actor’sNSAcE’s work planand subseqvent w&&ns

+ Ccwdinataa with the state/f&mtiilly respcnaible parties (PRPs) regarding site -

* Ensurea public awareness of RDiFcAa&vii

- Ensures al l appl icaMe or relevant and appropriate raqufrwwnts (ARARs) am fdantfffedforlhasite

* Plans necewy QA/GC activities

* Modtom, contrcb, and r&es schedule on regular basis

* Monitors, contrds, and revises bud@ on regufar basis

+ Audi pmjed execution

- Reviews key deliverablea and ensures quality products

* Manages WAS, IAGs, CAs, CDs, and other agrwmants

* Facilitates communicatfons between parties

* Llpdatas CERCl.BWasteL4N Systema

* Maintains admfnistrative recordMa fff

* Conducts final in-ion

- Reviews RArapor$

- Pr~WAdoseculreportwlwmaldosaoutnw)uestfa~IAG,~endaffxovasinvokes. and deobligatas any remafningfunds in WA, IAG, or CA

- --__ -,..~.._-.--

framework for undetstandmg the general and variednature of the position:

* Responsibilities during RDRA planning

* Responsibilities during~RD/RA execution

l Responsibilities during RDIRA closeout

f Limits of authority

* Potential liability

25.1 Res~ns~bil~~ DuringRWRAPlanning

The RPM is the key to successfulproject planningand should devote considerable time and energy to

-GE2

the phmmng aud startup phasesof the project. Themajority of fin& in the Superfundprogram are spenton RDs and RAS; consequently, it is important thateach RDRA project be successful. Ahhough eventhe most carefully planned and administered projectcan develop serious implementation problems, the

chances of this occurring are greatly reduced byadequately scoping the project and developing astrategyfor project hnplememation. When planningtbe RDFRA, the RPM must be aware of his or herrole, responsibilities, and level of authority to ensurethat the best plan for accomphsbing the objectivesis produced.

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RDlRAHandbook

Initially, the RPM should develop a projectmanagement plan (section 3.1) to serve as aframework for defining the RPM’s approach toproject execution. This enablesthe RPM to visuahxethe specifics of the project, make key decisionsregarding execution. consider constraints,and planaccordingly. The project management plan is anevolving document that is updated periodically asmore information is gathered and circumstanceschange. The purpose of theproject managementplanis to develop a strategy to complete the RD/RAsuccessfully. It is a particularly useful tool for theless experienced RPM who has not yet managed anRDlRA project. Less experienced RPMs shouldobtain assistancen preparing aproject managementplan from amore experiencedmanager. ExperiencedRPMs may find that they already perform a similarplanning exercise when scoping the project.

OSWER Directive 9355043, “Guidance forScoping the Remedial Desigq” (Publication No.PB95-963306), March 1995, provides moreinformation on scoping an RI3 project.

2.5.2 ResponsibllltiesDuringRD/RAExecution

After the initial planning is completed and the RD/RA begins, tire RPM is responsible for ensuring thatthe Projectprogresseson scheduleand within budgetTo do so, the RPM manages the EPA contractor,USACE, state, or potentially responsible parties

(PRFs) by:

initiating and maintaining frequentcommunications with project participants viaconference calls

Conducting regular meetings to discussRDIRA progress, identify problems, and takecorrective actions asnecessary

Developing complete documentation of allmeetings and conference calls

Ensuring timely review of key deliverables by

the TRT (section 3.4)

2.59 ResponsihilitkesuringWRA Closeout

Upon completion of the RDiRA, the RPM mustensure that the appropriate procedures are followedfor closing out the EPAcontractor WA, the USACE

LAG, the stateCA, or the PRP-lead activities. TheRPM also ensuresthat the proper transfer of sitestoparties responsible for operation and maintenance(O&M) of the remedy takesplace. For Federal-lead,Fund-financed sites,thestategenerally isresponsiblefor O&M and its responsibilities are outlined in theSSC. Chapter 5 and section 3.11 contain additionalinformation on theseresponsibilities.

2.5.4 LimitsofAuthority

During project execution, EPA enters intoagreements with a state, USACE, a contractor, orPRPs to accomplish all or part of the remedialactivities at the site. Even though the successfulcompletion of the RD/RA is the RPM’sresponsibility, he or she often does not have theauthority or ability to control all external infhwnces

that can impede tire project’s successfulcompletion.

For Federal-lead/EPA-managed RDs and RAs, theRPM must know the contracting structure of tireproject; the RPM cannot direct or assign work notspecified in contract documents (e.g., the SOW or aWA) or enforcement documents. The Contractingofficer (CO) is the only government official whocan authorize work beyond the original scopeof theWA. To prevent this from happening, the RPM mustdevelop a thorough SOW for the WA while bsingfamiliar with the terms and organization of allagreements with all the parties involved. ForSuperfund sites, the RPM usually functions as aWork Assignment Manager (WAM). Whenfunctioning asaWAM, the RPM should be aware ofhis or her limits of authority in directing andauthorizing work. As the CO is theonly governmentofticial authorized to commit govermnent funds inaWA, the RPM mustnot diit acontractor to initiatework before receiving authorization from the CO.

When USACE is the contracting party and managesthe RD or RA, personnel from USACE authorizetire work. The RPM should understand his or herrole and limits of authority and work within the limits

of the particular contractual agreement (the LAG).In addition to knowing his or her limit of authorityunder each type of agreement, the RPM mustadminister the necessary paperwork for theagreement. For ail types of agreements into which



Chapter 2. Pmject 88anqment

EPA enters with third parties to implementSuperfimd remedial activities, the RPM usuallyinitiates, monitors, revises (asnecessary),and closesout the agreements.

25.5 PotentialRPMLiability

The RPM should understandhis or her own habiiityand the liability of others during the performance ofthe RlmA.

RemedialDaslgn

Although the RPM approves the design anddeliverables before they are implemented, EPA’sreview and approval does not imply an assumptionof reapousibility for design deficiencies, errors, oromissions. Whenever the RPM submits reviewcommentsor approves adesign, the correspondenceshould include a clause that emphasizes that the

responsibiity for the effectiveness of thedesignrestswith the designer and that RPM “approval”constitutes only an authorization to proceed.L&wise. the RPM does not approve, ahhough heor she may appear to do so, other design-relateddeliverables such as the health and safety plan(HASP) and the quality assuratmeproject plan.

The RPM also must guard against directing thedesign contractor toward an unsound design. If theRPM does soand the implemented design fails, andthe contractor was not negligent in implementing

the design, then the design contmcmr’s liability isreducedor eliminated, regardlessof whether the RD/RA is a Federal-, state-,or enforcement-lead pmject.However, the RPM, as a federal employee, wouldnot be personally liable for government damagesresulting from directing the design contractorbecausegovernmen t employees are protected frompersonalliability incurred from performanCe of tbeii

9

job duties under the Federal Torts clahns Act. An

RPM could incur personal liability for damages,however, if the dnmages an the mwdf of an action

the RPM knowingly perfonncd outside the scope of

his or her job duties or area of competence.

To avoid thosesituations, the RPM should assemblea complete andcompet&TRTto review thoroughlythe design (see section 3.4). The RPM also shouldverify that the design contractor is com&ing with.its own design QA/ac plan.

ftemedlelAcgon

The RPM must respect the privity of contractbetween the contracting party and the constnwor.UnlessEPAhasacontractdirectly with aconstmctor,EPA must not direct the work of the constructor.Only the party contracting directly with the

constructor hasthe authority to do so. For example,during remediation activities, the RPM must becautious to ensure conformance with thespecifications without assuming responsibility forthe direction of the work of the constructor. Toaccomplish that, the RPM works with the EPAcontractor or USACE, which then diits the workof the constructor.

As with RJJ deliverables, EPA review and approvalof RA deliverables such as the HASP does notconstitute legal “approval.” For more specificinformation on legal liability, consuit the Office of

General Counsel or Regional Counsel.

lf an RA contract modification is requhed becauseof an error or deficiency in the design, the party thatcontracted for the design should examine thedesigner’s possible liabiity. If sufficient liabilityappearsto exist the designer may be held liable.

chap2 project management

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