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2022-04-18_REVISION - C2010089
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2022-04-18_REVISION - C2010089
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Last modified
4/18/2022 2:59:02 PM
Creation date
4/18/2022 2:55:22 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C2010089
IBM Index Class Name
Revision
Doc Date
4/18/2022
Doc Name
Adequacy Review Response
From
DRMS
To
Colowyo Coal Company
Type & Sequence
RN2
Email Name
JHB
THM
Media Type
D
Archive
No
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ACTION PLAN ID # UT-2017-001 <br /> findings and come to agreement on whether the identified questions represent areas for <br /> improvement in DOGM's cost estimation practices. Discussions will lead to a better <br /> understanding of DOGM's current practices,DFB's concerns and recommendations, and <br /> opportunities for improvement. <br /> ❑ DFB shall tailor Issue 4 of this Action Plan to address such areas of concern initially <br /> provided in PSD's findings and confirmed as an area in need of improvement during the <br /> DFB-DOGM in-person meeting. <br /> ❑ DOGM will make process improvements and ensure internal consistency among cost <br /> estimators and in a manner consistent with Tech-007 and the Utah program. Through the <br /> course of developing this Action Plan, DFB and DOGM have identified the following <br /> opportunities for improvement: <br /> ❑ Including overhead and profit in demolition costs per Tech-007. <br /> ❑ Ensuring equipment productivity rates and operating costs are used consistently. <br /> ❑ Ensuring structure demolition costs are representative of actual activities and <br /> reflect probable difficulty (e.g. size and reinforcement of footers,buildings with <br /> or without internal walls,conveyor systems,etc.) including haulage(number of <br /> trips and distance) and disposal costs. <br /> ❑ Improving accuracy of numbers by using local and rental costs in lieu of R.S. <br /> Means numbers where available(e.g. local seed sources, local disposal sites,etc.). <br /> ❑ Retaining documentation to support use of local cost amounts. <br /> ❑ Ensuring costs units are appropriate and consistent throughout a calculation (e.g. <br /> per acre or per square foot). <br /> ❑ Consider implementing peer review or other quality control checks to ensure <br /> consistent application of bond cost estimation procedures. <br /> ❑ If DOGM so chooses, it may incorporate any changes resulting from Issue 4 discussions <br /> into its internal procedures within Tech-007. If DOGM opts to revise Tech-007, it shall <br /> submit those revisions to DFB for review. <br /> ❑ DFB shall review any proposed changes to Tech-007 to ensure resolution of identified <br /> concerns and will provide feedback to DOGM as appropriate. <br /> ❑ DOGM shall further revise Tech-007 as appropriate to ensure resolution of identified <br /> concerns. <br /> ❑ DOGM shall finalize Tech-007 and obtain the necessary internal approvals required to <br /> finalize and implement the revised guidance document. <br /> ❑ DOGM shall prepare a letter notifying the regulated community of changes to its cost <br /> estimation procedures following the formal adoption of the revised Tech-007. <br /> ❑ DOGM shall implement all changes upon adoption of the revised Tech-007 after <br /> notifying operators of such changes. <br /> SCHEDULE: <br /> ❑ On March 27 through March 29,2017, DFB and DOGM will meet in Salt Lake City to <br /> discuss items identified in Issue 4. <br /> ❑ By April 28, 2017,DFB will revise Issue 4 to remove invalid concerns and clarify <br /> remaining areas for improvement. <br /> ❑ By May 30, 2017, DOGM will review the revised Action Plan and develop internal <br /> protocols for improving implementation of Tech-007. <br /> 11 <br />
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