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On March 1, 2013, CSXT issued Supplement 23 to tariff CSXT 8200-J that explained the Coal Load Profile (Appendix A); acceptable dust suppressant, application method (Appendix b) and the use of alternative products to latex based dust suppressants.
Since the issuance of this supplement there have been questions relating to the use and testing of alternative products (other than those containing latex). The following will address the questions about the Dust provision in general and also, offer more clarity on the use of an alternative product to latex.
If the conditions in Appendix B are utilized then the Freight Payer/Coal Origin Operator will be in compliance and nothing further will be required except certification to CSX with the chemical name and equipment. The certification should be:
A. On company letterhead (a PDF document if electronically submitted)
B. CSX Coal origin that the Vendor’s product was applied on.
C. Name of the Vendor supplying the product and name of the product.
D. Vendors recommend application quantity per rail car.
E. Signed by an authorized company representative.
Although not required, CSX would recommend that Freight Payer/Coal Origin Operators that choose a latex based product solution should consider testing and evaluation through SWA to mitigate any risk of product compatibility with their specific coal and validate their product-coal combination with SWA documentation.
Non-latex products can be used as explained in (A) (ITEM 2500 ) – (4) REQUIREMENTS FOR LOADING METALLURGICAL and PCI COAL. Basically, the alternative product must be tested and approved by Simpson Weather and Associates (SWA). It is important to note that a successful test approval by SWA will apply only to the particular CSX coal origin and coal sample submitted. A successful test from one CSX Coal Origin & coal sample will not mean that the alternative product has “blanket approval” from all CSX coal origins. Rather, separate tests will have to be conducted from each CSX coal origin along with a sample of coal that will be loaded at that location.
CSX is requesting that all non-latex based products be tested and have arranged for said testing to be done by Simpson Weather Associates (SWA), at a cost to the proposing Freight Payer and/or Origin Operator of $2,550 per product tested.
If an alternative product is tested successfully, SWA will supply the entity submitting the test with an “In-Transit Fugitive Coal Dust Suppressant Laboratory Evaluation Screening Success Form” that will have the CSX origin that the coal sample was taken from, date of the sample and date of the test. This document will ultimately be needed by CSX Coal Development when a CSX Origin Operator or Freight Payer submits an alternative product for use.
As a reminder, compliance to Supplement 23 is July 1, 2013. Please refer to the supplement 23 document for further information. You may also contact CSXT’s Office of Coal Development at email@example.com or 859-231-9027 with any questions you may have regarding the new tariff provision, and its implementation.
CSX Coal Development
Steve Crum Jeff Heath Kevin Kruse John Voelker