The parts of this that purport to end family separation are kinda like the Cheshire Cat—fading to nothing when you look closely. It’s administration policy to maintain family unity, “where appropriate and consistent with law and available resources.” whitehouse.gov/presidential-a…
Then in the very next sentence, “Congress's failure to act and court orders have put the Administration in the position of separating alien families to effectively enforce the law.” So keeping families together, by their lights, is not consistent with law.
Nothing in the EO approaches an order to anyone to keep families together. DHS Sec. is ordered to “maintain custody of alien families” in 3a. The word ‘together’ isn’t used. Contrast the language of 3b: “The Secretary shall not, however, detain an alien family *together* when..”
Separate issue: The way they’ve defined “alien families” excludes US citizen children of non-citizens. As I read it, the policy mandates separating e.g. children born in the states during the pendency of proceedings against alien parents (who’d be detained along w alien siblings)
Last thing: As noted above, 3b is really the only clear command regarding family unity, and it’s a prohibition. Moreover, its threshold is so loose “when there is a concern” (whose concern? past or present? based on evidence? gut feeling?) that it’s set up to swallow the policy. 
Imagine the DHS bureaucrat referring to this order trying to figure out whether a family will be kept together. There’s all the wishy-washy stuff about “available resources” and “where appropriate” and “consistent with law”—lots of risks for a bureaucrat to go that route. ...
Then there’s Section 3b, shining like a beacon of clarity in a sea of troubles. When there’s this concern, you “shall not” detain the family together—no exceptions, no qualifications. That one’s easy. Is there a concern? Find a concern, write it down, and your butt is covered.
