closeout report on the doe/sc cd-1 review of the · •the east pond (cooling pond) will be drained...

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OFFICE OF SCIENCE 1 Closeout Report on the DOE/SC CD-1 Review of the Integrated Engineering Research Center (IERC) Project Fermi National Accelerator Laboratory February 7-9, 2017 Ethan Merrill Committee Chair Office of Science, U.S. Department of Energy http://www.science.doe.gov/opa/

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Page 1: Closeout Report on the DOE/SC CD-1 Review of the · •The East Pond (cooling pond) will be drained and filled with on-site material ... systems, green roof, solar hot water and all

OFFICE OF

SCIENCE

1

Closeout Report on the

DOE/SC CD-1 Review of the

Integrated Engineering Research Center

(IERC) Project

Fermi National Accelerator LaboratoryFebruary 7-9, 2017

Ethan Merrill

Committee Chair

Office of Science, U.S. Department of Energy

http://www.science.doe.gov/opa/

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OFFICE OF

SCIENCEReview Committee

Participants

2

Ethan Merrill, DOE/SC, Chairperson

Review Committee

Subcommittee 1: Technical and ES&H

*Marty Fallier, BNL

Ben Maxwell, LBNL

Bill Rainey, TJNAF

Subcommittee 2: Cost and Schedule

*Jerry Kao, DOE/ASO

Jason Budd, ANL

Subcommittee 3: Project Management

*Steve Cannella, BNL

Gary Bloom, ORNL

*Lead

Observers

Stephanie Short, DOE/SC

Gary Brown, DOE/SC

Steve Neus, DOE/FSO

Mike Fenn, DOE/PM

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OFFICE OF

SCIENCE

3

Charge Questions

1. Have performance requirements been appropriately and sufficiently defined for this stage of

the project?

2. Has a credible and sufficient alternatives analysis been performed? Are project risks identified

and has a credible Risk Management Plan been developed?

3. Are the estimated cost and schedule ranges supporting the most likely alternatives credible and

realistic for this stage of the project? Are scope, cost, and schedule contingency amounts

adequate? Are there sufficient scope trade-offs and building attributes to be provided to the

building designers to accommodate either bids greater than the estimate or less than the

estimate?

4. Is the project being appropriately managed? Is the Integrated Project Team established and

functioning?

5. Are environment, safety and health aspects being properly addressed given the project’s

current stage of development? Are Integrated Safety Management principles being followed?

6. Are project documents (e.g., Acquisition Strategy, Preliminary Project Execution Plan, and

Preliminary Hazard Analysis Report) complete and ready for approval? Is the project ready

for CD-1?

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OFFICE OF

SCIENCE

1. Have performance requirements been appropriately and

sufficiently defined for this stage of the project?

Yes, with minor qualification.

2. Has a credible and sufficient alternatives analysis been performed?

Are project risks identified and has a credible Risk Management

Plan been developed?

Yes, both the AoA and RMP are credible and the Risk Register

is thorough and comprehensive with regard to technical scope

6. Are project documents (e.g., Acquisition Strategy, Preliminary

Project Execution Plan, and Preliminary Hazard Analysis Report)

complete and ready for approval? Is the project ready for CD-1?

Yes, documents are complete - the project is ready for CD-1

4

2. Technical

M. Fallier, BNL / B. Maxwell, LBNL / W.

Rainey TJNAF - Subcommittee 1

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OFFICE OF

SCIENCE

2. Technical

M. Fallier, BNL / B. Maxwell, LBNL /

W. Rainey TJNAF - Subcommittee 1

5

Findings

• The IERC is necessary to support the LBNF program at FNAL which is

recognized as a top priority of the P5 committee for the HEP program

• LBNF is part of a large international consortium of users that are investing in

the program and are expected to significantly increase the campus population

• The master campus plan presented the IERC as a top priority to consolidate

remotely dispersed staff and provide facilities to improve efficiency and

collaboration of staff in support of the science mission

• Threshold KPPs of 87,500 SF, Target of 97,500 SF and Objective of 130,000 SF

• Schedule based on a funding profile initiating design in 2017 and completing

delivery in 2020 with an added 24 months float to CD-4

• Cost range of $73M - $86M TPC, with target cost of $86M at 97,500 SF

• P5 science drivers, plans for US particle physic and DOE SC 10 year plan

indicate FNAL collaboration with LHC-CMS experiment and leading the

LBNF neutrino research program

• A FNAL science requirements task force established the program needs for the

IERC including: detector R&D space; lab space with dedicated labs; clean

rooms and lab support; office & technical space; shared space for collaboration

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OFFICE OF

SCIENCE

2. Technical

M. Fallier, BNL / B. Maxwell, LBNL /

W. Rainey TJNAF - Subcommittee 1

6

Findings

• Flexible space is a key design consideration enabling response to future changes

• Alternatives analysis considered five options, 2 were rejected as not mission

capable. Build New, Improve Existing and Renovate Existing options

underwent LCC - Build New option had lowest LCC by nearly a factor of two

• Design charrettes for the CDR included notable independent architects in

addition to contracted A/E and on-site team

• Site selection for the new building considered impact on the iconic Wilson hall,

shadow impacts, parking impacts and collaboration feasibility among others.

• Four high rank risks were identified from a risk registry listing 49 risks &

technical risks were medium to minor

• The East Pond (cooling pond) will be drained and filled with on-site material

and is not considered a wetland

• A commissioning contractor will be used during design and construction

• The IERC will not result in changes to site security requirements

• NEPA review has been completed and is approved as Categorical Exclusion

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OFFICE OF

SCIENCE

2. Technical

M. Fallier, BNL / B. Maxwell, LBNL /

W. Rainey TJNAF - Subcommittee 1

7

Findings

• The planned science & engineering activities includes Si detector development

but aggressive etching chemicals are not expected to be used in the process

• Plan is for only a gas/chemical inventory that will enable Class B occupancy and

includes no flammables. Thus only very small inventory of some gases will be

allowed. Not expecting corrosives and reactives.

• Interior design focuses on “collaboration commons” areas to assure many

spontaneous scientific interactions among staff

• Lab exhaust runs through an interstitial space horizontally along the full length

of the bldg. before going up a vertical chase which is near to Wilson Hall

• A utility analysis was conducted and plan to relocate existing utilities (power,

water, cooling water, storm and sanitary) in the footprint of the building. A

major communication duct may be able to remain.

• Sustainability features include VAV HVAC, use of outside air, chilled beam

systems, green roof, solar hot water and all LED lighting

• The project identified 55,000 SF as available for demolition but is not included

in the project cost

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OFFICE OF

SCIENCE

2. Technical

M. Fallier, BNL / B. Maxwell, LBNL /

W. Rainey TJNAF - Subcommittee 1

8

Findings

• Cooling capacity and boiler capacity from CUB is limited and will need to be

supplemented. Plan to use heat recovery chiller (heat pump) of about 200 tons

to supplement cooling and provide comparable energy amount for heating

• Electrical system will separate lab power from bldg. power to provide a clean

power system

• Plans include 250kw emergency generator for life safety loads, standby loads

for selected equipment, elevator and certain lab equipment & exhausts

• At this time, need for specific vibration criteria are not determined so heavier

steel and concrete and added isolation are not included in the estimate

• Objective scope includes a Wilson Hall stairway at the northwest entry which is

an important improvement to flow and includes a ramp for ADA accessibility

• The target scope does not include a seminar space but seminar space is

proposed as part of the objective scope

• Plans to add or delete scope are very conceptual at this stage and are described

in terms of functional space but not physically represented in the current

design. They propose to involve listing one or more central bays as additive or

deduct scope as the design advances

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OFFICE OF

SCIENCE

2. Technical

M. Fallier, BNL / B. Maxwell, LBNL /

W. Rainey TJNAF - Subcommittee 1

9

Comments

• The programmatic and mission need drivers for the facility are clear - the

current dispersed, old, non-purpose-built facilities do not adequately support

the intended growth in program needs and do not support collaboration and

was reinforced by the tour of facilities

• Although there may be opportunities to improve the case for the preferred

solution, the alternatives analysis reached a credible conclusion that building a

new facility adjacent Wilson Hall provides the lowest LCC and is most effective

at reaching mission need

• The approach for the proposed alternative is based on a robust site planning

effort and is consistent with the site master plan

• The program development included a thorough process of outreach to

determine technical scope and program requirements including A/E design

charettes

• The CDR team had a unique challenge in marrying a new facility to Wilson

Hall without detracting from its iconic visage. The team is commended for

finding a functional and attractive architectural solution that retains Wilson

Halls command of the site.

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OFFICE OF

SCIENCE

2. Technical

M. Fallier, BNL / B. Maxwell, LBNL /

W. Rainey TJNAF - Subcommittee 1

10

Comments - continued

• As a combined lab/office building, the current design does not include

conservative assumptions about possible future need for stringent vibration,

temperature and EMI/RFI criteria. If these needs (which are becoming typical at

many sites) arise it can add substantially to cost

• Overall impression of the technical deliverables vs target estimate - the estimate

may be low given the high proportion of lab space and clean room space with

potential for more demanding requirements as the design evolves

• The current lab exhaust design involves a long horizontal run to a vertical exhaust

chase at the Wilson Hall end of the IERC and plume modeling has not been done

yet. The project should consider integrating exhaust on the East side as a shorter

run further from Wilson Hall

• The CDR is well developed and thorough however potential scope contingency is

not graphically identified yet but the project has identified functions that can be

omitted if required.

• Current threshold deliverable technical scope is 87,500 SF and target scope is

97,500 SF and objective scope is 130,000 SF. The target scope may not be

achievable (assuming fully functional buildout) at target cost given the full range

of risks and design uncertainty at this stage of development

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OFFICE OF

SCIENCE

2. Technical

M. Fallier, BNL / B. Maxwell, LBNL /

W. Rainey TJNAF - Subcommittee 1

11

Recommendations

• Strive to resolve definitive environmental requirements for labs and

cleanrooms so the impacts are incorporated in the estimate prior to CD-2

• Assure that methods to decrease deliverable scope to achieve threshold KPPs

can be integrated in the project design before CD-2

• Proceed to CD-1

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OFFICE OF

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12

3. Cost and Schedule

J. Kao, DOE/ASO, J Budd, ANL

Subcommittee 2

2. Has a credible and sufficient alternatives analysis been performed? Yes

Are project risks identified and has a credible Risk Management Plan been

developed? Yes

3. Are the estimated cost and schedule ranges supporting the most likely

alternatives credible and realistic for this stage of the project? No

Are scope, cost, and schedule contingency amounts adequate? Yes

Are there sufficient scope trade-offs and building attributes to be provided to

the building designers to accommodate either bids greater than the estimate

or less than the estimate? Yes

6. Are project documents (e.g., Acquisition Strategy, Preliminary Project

Execution Plan, and Preliminary Hazard Analysis Report) complete and

ready for approval? Yes Is the project ready for CD-1? Yes

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OFFICE OF

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13

Findings

• The Total Project Cost (TPC) range is $74.0M - $86.0M and is based solely on the

proposed alternative of constructing a new multi-use building. The high end

completes 97,500 SF which represents the threshold scope and a portion of objective

scope being used as scope contingency (10K SF), 23% cost contingency to go

($15.84M), no separate design contingency, 3-4% escalation, and general

condition/OH/profit of 12.4% of construction.

• The proposed $86.0M point estimate used to develop the cost range is the high end

cost. The low end represents -15% factor of the point estimate based on the DOE

cost estimating guide at this stage of the project.

• A bottoms up third party and A/E conceptual cost estimate was developed and were

within 0.5% of each other when disregarding General conditions, design

contingency, and escalation.

• The project has identified $13.2M in estimate uncertainty and $2.7M in 90% CL

expected risk (when eliminating the duplicate items) totaling $15.9M.

3. Cost and Schedule

J. Kao, DOE/ASO, J Budd, ANL

Subcommittee 2

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OFFICE OF

SCIENCE

14

Findings

• CD-4 is currently planned for 2Q FY24 with 23 months of schedule contingency.

Early finish is scheduled for March 2020.

• There currently is no external project dependencies driving the CD-4 date.

• This schedule currently includes long lead procurement (CD-3a) approval for site

preparation involving draining the east reflection pond, parking lot removal, and

utilities.

• Equipment and personnel moves are planned to be done off project.

• The project has developed a preliminary resource loaded schedule with 76 activities

and 83 milestones.

• The project has developed a schedule based on the assumption of a 3 month CR in

all Fiscal Years including FY17.

• The early finish date is based on obtaining CD-2/3a (site preparation) and PED

funding in FY17.

• Project has run an Acumen fuse schedule diagnostics.

3. Cost and Schedule

J. Kao, DOE/ASO, J Budd, ANL

Subcommittee 2

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OFFICE OF

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Findings

• The critical path runs through a preliminary design, final design, and then

construction. Building construction is scheduled to take 27 months to complete.

• The project is scheduled to receive $2.5M in PED funds in FY17, but may not

receive these funds if there is a year long CR. Site Prep activities are scheduled to

start 4Q FY18 and is not considered to be on the critical path. The project risk

register has identified an expected 6 month delay due to an FY17 CR.

• The risk registry identified 45 risks and 4 opportunities. A preliminary risk cost and

schedule Monte Carlo analysis was performed showing 90% confidence of

completing the project with 19 months schedule contingency and $8.4M in cost

contingency.

• The high risk items identified include a FY17 funding delay, CM/GC proposals

coming in too high, trade package bids coming in too high, and a change in indirect

rates.

• A Risk Management Plan was developed and the project is currently holding

quarterly meetings to review and update risks. Monthly meetings will occur after

CD-1 approval.

• The $86.0 TPC includes an EDIA percentage of approximately 20%.

3. Cost and Schedule

J. Kao, DOE/ASO, J Budd, ANL

Subcommittee 2

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OFFICE OF

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Findings

• No external dependencies are specifically identified in the cost estimate or schedule.

• The project analyzed 5 different alternative strategies. It was determined that

alternatives 1, 2, and 3 were viable and further analyzed. The total life cycle cost for

alt. 3 ($191M) was the lowest when compared to alt. 1 ($331M) and alt. 2 ($368M).

1.) Improve Existing

2.) Renovate Existing

3.) Construct New Building (next to Wilson Hall or in the Technical Campus)

4.) Retain Building Status Quo

5.) Construct New Building at Another Laboratory

• The analysis used a 50 year service life. The major cost difference between the

improve/renovate existing and the new construction alternatives is the annual

productivity loss avoidance cost of $2.74M per year. This contributes to a majority

of the difference in the analyzed alternatives.

• A scoring system was also performed which ranked the alternatives according to

NPV, Collaboration, Modern mission-ready facilities, ES&H, and Location / Site

Condition. Alternative 3 ranked highest in all of the criterion.

3. Cost and Schedule

J. Kao, DOE/ASO, J Budd, ANL

Subcommittee 2

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Comments

• The project has completed a thorough analysis of several alternatives and the

proposed renovation of New Construction appears to be the best and lowest cost

alternative to fulfill the mission gap.

• Consider updating the AoA with respect to the cost inputs in the renovation and

improving existing space alternatives by refining or evaluating the need to include

the productivity loss calculation. This cost input does not appear to change the NPV

rankings.

• The cost presented for the WBS 602.4 Construction ($57,640K) in the PPEP did not

match the cost estimate presented ($55,455K). Ensure that the BOE matches the

independent cost estimate going forward.

• When estimating general conditions and overhead in the construction estimate,

ensure the additional cost of performing work in a DOE national lab is incorporated.

For example, DOE safety and EVMS requirements are not costs that are typically

incorporated in a University or private sector construction project.

3. Cost and Schedule

J. Kao, DOE/ASO, J Budd, ANL

Subcommittee 2

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Comments

• The proposed TPC point estimate of $86.0M appears adequate to meet the threshold

KPP SF. The amount of cost contingency is also considered adequate at this stage of

the project. The project’s cost estimate, which was independently estimated from

bottom’s up, is further along than the typical conceptual design cost estimate.

• The project team also performed a parametric comparison with a recent and

geographically close SLI project, ANL’s MDL, which at CD-1 estimated $762/SF

compared to IERC’s calculated $591/SF at 97,500 SF, and $659/SF at 87,500 SF.

Since there are significant scope differences between IERC and MDL, and two

bottom’s up cost estimates were performed by the project, IERC’s $/SF appears

reasonable.

• Consider including design contingency into the construction cost to account for

unknown design issues/scope that may be identified during remaining design

development. Having design contingency included in the cost estimate at this stage

of the project is a prudent practice.

3. Cost and Schedule

J. Kao, DOE/ASO, J Budd, ANL

Subcommittee 2

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Comments

• The DOE cost estimating guide suggests a minimum +20% factor for the high end

along with a minimum -15% factor for the low end when determining a cost range

around a Level 4 point estimate. Consider adjusting the high end of the cost range to

account for the +20% factor.

• The CD-4 date of February FY24 with 23 months of schedule contingency appears

realistic and achievable.

• If a full year FY17 occurs, the early completion date may push back up to a year, and

the point estimate may rise due to construction escalation costs.

• Due to the high probability of occurrence, consider accepting the FY17 CR delay

risk and adjusting the project schedule and cost accordingly.

• The proposed cost ($15.843M) and schedule contingencies (23 months) presented

appear adequate and were validated qualitative analysis and Monte Carlo analysis.

3. Cost and Schedule

J. Kao, DOE/ASO, J Budd, ANL

Subcommittee 2

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Comments

• The committee supports performing the site preparation activities as soon as possible

using a CD-3a or PME letter approval. Doing so shortens the duration of the project,

reduces overall project costs, and reduces potential risks associated with the

relocation of underground utilities.

• The 90/100/110 approach where 100% is the 97,500 SF “design to cost” scope of the

A/E and the 90% is the threshold KPP of 87,500 SF appears sound. This will allow

for a design with a clear deductive option in the event construction bids are high.

• As design progresses, ensure scope contingency deducts total at least 10% in

estimated construction cost during preliminary and final design.

• The risks in the register appear thorough and complete at this stage of the project.

• Consider adding level III milestones into the PPEP.

• By completing a P6 resource loaded schedule, the project is in good position to begin

EVMS reporting when appropriate.

• The project is incorporating best practices in incorporating Acumen Fuse and DCMA

schedule analysis at CD-1 which confirms high degree of schedule logic.

3. Cost and Schedule

J. Kao, DOE/ASO, J Budd, ANL

Subcommittee 2

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Recommendations

• Re-evaluate the high end of the cost range prior to CD-1 approval.

3. Cost and Schedule

J. Kao, DOE/ASO, J Budd, ANL

Subcommittee 2

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PROJECT STATUS – Pre CD-1 as of 2/2/2017

Project Type Line Item

CD-1 Planned: 3Q FY17 Actual:

CD-2/3A Planned: 3Q FY19 Actual:

CD-3B Planned: 3Q FY20 Actual:

CD-4 Planned: 2Q FY24 Actual:

TPC Percent Complete Planned: __NA___% Actual: _____%

TPC Cost to Date $847,100 (OPC)

TPC Committed to Date $847,100 (OPC)

TPC - Preliminary Range $74M - $86M

TEC – Preliminary Range $73M - $85M

Contingency Cost – Preliminary $15.84M __

Contingency Schedule on CD-4 – Preliminary _23 months __

CPI Cumulative NA

SPI Cumulative NA

3. Cost and Schedule

J. Kao, DOE/ASO, J Budd, ANL

Subcommittee 2

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4. Environment, Safety, and HealthB. Rainey, TJNAF

5. Are environment, safety and health aspects being properly addressed

given the project’s current stage of development? Are Integrated

Safety Management principles being followed? YES

6. Are project documents (e.g., Acquisition Strategy, Preliminary

Project Execution Plan, and Preliminary Hazard Analysis Report)

complete and ready for approval? Is the project ready for CD-1?

YES – all ready for CD-1.

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• Findings

• ES&H aspects, appropriate to this level of project design, are being addressed with

respect to risk and requirements analysis, acquisition plans and conceptual

designs.

• Fermilab’s existing programs and systems (ISM, WS&HMP, EMS, EMP) are in

place and related operational controls should continue to positively impact project

development.

• The project will not change Fermilab’s safeguards and security requirements.

• IERC siting related S&H issues such as traffic and pedestrian flow, construction

safety, beamline considerations and interactions with Wilson Hall have been

recognized and mitigation strategies are at the appropriate stages of development.

• Project documents (e.g., Acquisition Strategy, Preliminary Project Execution Plan,

and Preliminary Hazard Analysis Report, NEPA CX) are in place and reflect

project ES&H aspects.

24

4. Environment, Safety, and HealthB. Rainey, TJNAF

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• Comments

• Updating IERC’s expected/projected chemical and gas inventory and

emission/waste generation should be completed prior to CD-2 to support design

efforts and regulatory impact analysis.

• Recommendations

• Proceed to CD-1

25

4. Environment, Safety, and HealthB. Rainey, TJNAF

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5. ManagementS. Cannella, BNL / G. Bloom, ORNL

Subcommittee 3

2. Has a credible and sufficient alternatives analysis been performed?

Yes. Are project risks identified and has a credible Risk

Management Plan been developed? Yes.

4. Is the project being appropriately managed? Yes. Is the

Integrated Project Team established and functioning? Yes.

6. Are project documents (e.g., Acquisition Strategy, Preliminary

Project Execution Plan, and Preliminary Hazard Analysis Report)

complete and ready for approval? No. Is the project ready for CD-

1? No.

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5. ManagementS. Cannella, BNL / G. Bloom, ORNL

Subcommittee 3

Findings

• The project Key Performance Parameters have a scope Threshold Value of

87,500gsf and an Objective Value of 130,000gsf and Site Improvements.

• The project Total Estimated Cost Range is $73M-$86M.

• The Project has an overall cost contingency of $15.8M on TEC or 23.3% on

the to-go –cost. Preliminary EDIA has been calculated at 14% of TEC which

is in-line with similar/recent SLI projects.

• A credible Analysis of Alternatives has been completed resulting in the

identification of the New Building alternative as the preferred solution to

satisfying the Mission Need. Both qualitative sensitivity analysis and

quantitative Building Life Cycle Cost analysis was performed.

• The Fermi lab-standard Risk Management policy/procedure utilized by the

IERC team is well defined and thorough.

• The IERC Risk Registry has been appropriately prepared for CD-1. 45 risks

and 4 opportunities have been identified. Opportunities have not been included

in the Monte Carlo Analysis.

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5. ManagementS. Cannella, BNL / G. Bloom, ORNL

Subcommittee 3

Findings

• The High Level Risks have been identified…

1. High CM/GC proposals

2. High Subcontractor Bids

3. FY17 Funding delay due to CR

4. Changes in Fermilab indirect rates

• The CDR program is mature for this stage of the project and the preliminary

performance requirements have been established. A high level of program

participation and support is evident.

• The IERC project is aligned strategically to the “Building for Discovery”

(Particle Physics P5 Plan) and the Fermi Annual Lab Plan.

• A CD-1 Director's review was held August 2016. The project has adequately

addressed the management comments from this review

• A comprehensive and experienced IERC project team is in place for the

execution of the project with experienced control account managers (CAMs).

• Project Management

• Design

• Construction

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5. ManagementS. Cannella, BNL / G. Bloom, ORNL

Subcommittee 3

Findings

• Procurement plans are in place for the acquisition of AE and CM/GC services

that are thorough and well planned.

• The project has determined that the facility will not be a nuclear facility,

commonly referred to as a radiological facility or radiological activities, as

defined in 10 CFR 830. The 10 CFR 830 requirements have not been flowed

down into sub-contract requirements for design and construction of the facility.

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5. ManagementS. Cannella, BNL / G. Bloom, ORNL

Subcommittee 3

Comments

• The project has overall adequate cost and schedule contingency for this stage of

project development.

• Consider updating project documents to clearly identify key project information

as “Preliminary” (i.e. Preliminary KPP, Schedule, Milestones).

• IERC is to be commended for the level of team experience and qualifications.

• The assignment of an experienced architect to manage the design process is

commendable .

• Consider removing the Analysis of Alternatives from the Acquisition Strategy

to create a stand alone document

• Consider further definition of the project strategy of 90/100/110 scope by early

identification design scope that will support the Preliminary Key Performance

Parameters.

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5. ManagementS. Cannella, BNL / G. Bloom, ORNL

Subcommittee 3

Comments

• Consider design strategies that support future growth and/or changes in the

facility requirements.

• Suggest obtaining official program/user sign-off/approval on Basis of Design

and/or programming requirements documentation.

• Consider revisiting the Analysis of Alternatives to ensure costs associated with

maintenance, deferred maintenance and repairs, cost of missed collaboration

opportunities, and facility cost of excess facilities are adequately addressed.

• The Analysis of Alternatives sensitivity analysis utilized a 25% weighted value

for Net Present Value. Consider evaluating this weighing factor to ensure it

provides the proper weighting score to the qualitative analysis.

• Consider radiological protection review of proposed facility activities to ensure

that the facility will not need to be classified now or in the future as a nuclear

facility as defined in 10 CFR 830.

• The risk probability associated with risk items 602.32 Changes in

Programming, and 602.33 Errors and Omissions, appear to be low. Consider

continued evaluation of risk probabilities with the Risk Management Board.

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5. ManagementS. Cannella, BNL / G. Bloom, ORNL

Subcommittee 3

Recommendations

• Update Preliminary KPP table to omit the “Site Improvements” prior to CD-1.

• Create a stand alone Alternatives of Analysis document prior to CD-1.

• Update appropriate required CD-1documents prior to CD-1.

• Upon completion of recommendations proceed to CD-1.