333 W. Vine Street – Suite 206
Lexington, Kentucky 40507
(859) 231-9027
FAX (859) 231-9449

Steven J. Crum
Director - Coal Development

March 1, 2012

Dear CSXT Producer:

In recent years, CSX Transportation (CSXT) has received complaints from private citizens and citations from governmental agencies concerning coal train fugitive dust emissions. Some states, through which your coal travels by rail, have regulations that prohibit the discharge of visible fugitive dust emissions beyond the railroad right-of-way.

CSXT believes this issue, like all environmental issues associated with the transportation of coal, is one that coal shippers and transporters need to respond to in a proactive manner. 

The Coal Mining Industry has considerable experience addressing dust emission problems occurring during the mining and preparation process. Different methods of controlling emissions - from applying water spray systems to other more sophisticated suppressants - have been employed successfully, allowing the Industry to continue to mine and process coal. Since the Industry is well aware of the need to control dust emissions, you can appreciate that in order to ship your coal, we must address the issue together.

CSXT advises all coal shippers to apply a dust suppressant agent, in sufficient quantity (when a freeze conditioning agent is not utilized), to prevent rail car fugitive dust emissions.  However, those Coal Producers that ship metallurgical, low moisture, low ash or extremely fine coal products, must ensure prevention of rail car dust emissions by using a dust suppressant agent.

Such applications appear to have been very effective in addressing the dust emission issues in the past.  When rail car dust emissions occur, CSXT may have no recourse but to pass on to your company the costs of all environmental citations and associated expenses incurred by CSXT. CSXT, also reserves the right to not supply rail cars to any shipper whose coal shipments, while being transported on CSXT, have been cited for dust emissions until an effective dust suppressant agent is applied on future shipments.

Rail Car Safety
It is important that care is taken not to over spray dust suppressant during the application process.  Due to Department of Transportation and CSXT safety rules, CSXT cannot accept rail cars that have a dust suppressant coating on the safety appliances of the rail equipment.  These safety appliances include side ladders, sill steps, hand brakes and walking / standing platforms on rail cars.  When a dust suppressant is dripping off the safety appliances or coats more than 20% of the surface of the rail car’s safety appliances with a visible sheen, CSX cannot accept the rail car for transport.  

When a Dust Suppressant is applied to a rail shipment, please note the product utilized and the quantity of the product applied on the electronic bill of lading document, in the “special handling” field:

(H3 segment for EDI billing,

Special Handling and Comments section for ShipCSX users),

For those customers submitting Bills of Lading via ShipCSX, please follow these steps for entering the information:
Click on “Special Handling and Comments,” under the “Comments” section, place your comments in regards to your Dust Suppressant application. 

Note that the @ sign is required and MUST be used prior to entering any information.
Example:  @Dust Suppressant Product Name applied 8 gallons per car
 
This will provide hard copy verification, that the coal has been treated.
                
We appreciate your understanding and look forward to working with you to continue to make coal an environmentally acceptable choice.

Please contact the Coal Development office at 800-852-4923 for additional information.   We appreciate your choice of CSXT for your shipping needs.

Yours truly,
Steven J. Crum