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2014-10-21_REVISION - C1981044
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2014-10-21_REVISION - C1981044
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Entry Properties
Last modified
8/24/2016 5:49:09 PM
Creation date
10/21/2014 12:51:51 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981044
IBM Index Class Name
Revision
Doc Date
10/21/2014
Doc Name
4th Adequacy Review
From
Twentymile Coal Company
To
DRMS
Type & Sequence
TR36
Email Name
JLE
DIH
Media Type
D
Archive
No
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a. MCM Response: The current insurance certificate is included with the <br />responses for replacement in Exhibit 1. <br />b. DRMS Response: Please address the following items in regards to the updated <br />certificate of liability insurance: <br />i. The certificate holder listed on the updated form is Routt County Board <br />of Commissioners. The Colorado Division of Reclamation, Mining and <br />Safety should be listed as the certificate holder. <br />ii. Please clarify which coverage limits listed on the form covers bodily <br />injury. <br />iii. Please clarify which coverage limits listed on the form covers property <br />damage. <br />iv. Under the "Description of Operations /LocationsNehicles" section of the <br />form, indicates the policy covers Peabody Sage Creek Mining, LLC. <br />And not Moffat County Mining. Also, this section indicates the <br />insurance policy covers operations in Routt and Moffat Counties, <br />Colorado and Carbon County, Wyoming as well as the Mesa Gravel Pit. <br />Given this, it is unclear if the coverage limits meets the minimum <br />coverage required by Rule 2.03.9(1) for bodily injury and property <br />damage for the Williams Fork Mines. Please clarify. <br />MCM Response: <br />i. Attached is an insurance certificate showing the CDRMS as a listed <br />certificate holder. <br />ii. As an aggregate corporate liability insurance policy, the policy is <br />designed to cover liability for any loss including bodily injury or <br />property damage, and also includes some additional specific liability <br />coverages, as noted in the policy. Relative to the minimum liability <br />coverage required under Rule 2.03.9, both the "Each Occurrence" and <br />"Aggregate" coverages under the relevant policy are well above the <br />minimums specified. <br />iii. The "Additional Remarks" section on page 2 of the existing certificate is <br />a carry-over of the information in the referenced section, and does <br />include Williams Fork Mines — Moffat County Mining, LLC. The <br />concern with coverage limits under the combined certificate has <br />previously been addressed with the CDRMS (see attached e-mail) and <br />the CDRMS reviewed and approved the combined certificate with the <br />current wording and designations. <br />d. DRMS Response: This item is resolved. <br />Rule 2.05.3 — Operation Plan — Permit Area <br />4) Revised Page 2.05 -16 indicates a number of roads will be left in place after reclamation <br />to support the post mining land use. The currently approved Map 29 clearly delineates <br />which roads will remain after reclamation. The revised Map 29 does not delineate <br />which roads will remain after reclamation. In accordance with Rule 4.03.1(1)(f) and <br />4.03.2(1)(g) requires that all haul and access road be reclaimed unless they will be used <br />in accordance with the post mine land use and the landowner requests to the Division in <br />writing that the road or certain parts be left in place for future use. For each road <br />intended to be left in place, please provide the Division with written approval from the <br />landowner(s) or commit to supplying this information prior to bond release. This <br />
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