Eagle Pass and the Dos Republicas Coal Mine/OPINION
By: George Baxter
Dos Republicas Coal Partnership, a wholly owned subsidiary of Mexican corporation Altos Hornos de Mexico, S.A. de C.V. (AHMSA), is currently applying to the Railroad Commission of Texas to renew, revise and expand its current permit 42A to operate an open pit coal mine in Maverick County, a few miles north of Eagle Pass. Dos Republicas is seeking to enlarge the area of the mine to about 6346 acres or 10 square miles. If the permit is granted, Dos Republicas has stated that it will begin building infrastructure in 2012 and start strip mining in 2013.
One of the many hazards to public health created by this mine is dust both from the excavated soil and from the coal itself. This dust comes from several different sources: from the overburden soil as it is excavated and stored in large stockpiles, from the coal as it is extracted and moved to the rail loading facility, from the heavy mining trucks moving constantly on the dirt haulroads, from the loading terminal as the coal is loaded into the railcars and from the railroad cars as the coal is moved through town on its way to Mexico.
As the mine is excavated, large areas will have all native vegetation removed and large quantities of topsoil, subsoil and overburden (the material between the subsoil and the coal) will be dug out and placed in huge storage piles (up to 4000’ by 1300’ by 50’ high). When the wind blows from the north, as it does in the winter months, quantities of dust will be blown out of the permit area into surrounding communities such as Deer Run, Seco Mines and perhaps into Eagle Pass itself. Dos Republicas’ plan to control this is to plant “quick growing vegetative cover” on these stockpiles. However, in response to questions, Dos Republicas is unable to say how much water will be necessary to make these plants grow over such large areas.
Similarly, Dos Republicas is unable to say how much water will be necessary for dust suppression on the haulroads, which is the major source of dust within the permit area. Dos Republicas’ permit application states that “fugitive dust control emission control measures include watering and/or chemical treatment for soil stabilization.” However, during the public hearing on the mine held here in June, Dos Republicas stated several times that “We don’t use any chemicals.” Beyond this contradiction, there is the huge question of water availability. Dos Republicas does have access to some water from the Maverick County Water Control and Improvement District, but much of it is restricted to be used only for irrigation purposes and only on certain specified areas. During the public hearing, Dos Republicas said that they did not know how much water they would need on a daily basis to operate the mine but that most of it would come from an agreement they have with the City of Eagle Pass to use treated city water. However, a large fraction of the water available for this source must be piped to the Burr Ranch to replace water loss caused by the operation of the mine. So, it is unknown to the residents of Maverick County (and perhaps to Dos Republicas itself) whether or not they have sufficient water available to adequately suppress fugitive dust, especially during hot, dry or windy periods.
Even with sufficient water for roadway dust control, the U.S. Public Health Service states that “watering [haulroads] once an hour resulted in a [dust] control efficiency of 40%. Doubling this application rate increased control effectiveness to 55%.” This leaves a lot of dust still subject to be blown out of the mine area into surrounding residential zones.
The coal found on this mine site is extremely high in ash (the substances within the coal which do not burn). This ash composes anywhere from 20% to 50% of the coal mined by weight and the ash itself has a very high silica (silicon dioxide) content (50% – 70%). This coal will be broken up in the pits and loaded into large trucks for transport to the rail loading facility. Dos Republicas has stated that as much as 130,000 tons (or over 3 million cubic feet) of coal will be stored in the permit area at any one time. This coal stockpile will also be exposed to wind erosion. Likewise, during the railcar loading process, coal dust may be blown out of the permit area on windy days. There are procedures that Dos Republicas could take to limit the amount of dust escaping from these last two sources, but their permit application is very general and vague in this area, so it is not known if any of these steps will be taken.
According to the Peninsula Clarion (Seward, Alaska, January 24, 2011), “A clean water lawsuit alleging violations by the Seward Coal Loading Facility was allowed to go forward by federal district Judge Timothy Burgess.” “Seward residents say that the coal dust from operations creates both a nuisance and a public health hazard.” “The coal dust blows off the facility’s two massive stockpiles into the bay, covering nearby fishing charter boats and nearby neighborhoods with dust and debris.”
Likewise, Sourcewatch.org states that “on more than one occasion, coal dust from the Brayton Point Station has covered the neighborhoods of Somerset, Massachusetts.” “The coal dust has been carried from the Station while deliveries of coal were unloaded from the ships on windy days. On October 29, 2008, coal dust covered nearby Ripley Street where residents reported having coal dust in their homes despite the windows being closed. A 45,000 ton shipment of coal was unloaded overnight and the community awoke to the dust the following morning.” [Each train at the Dos Republicas Mine will be loaded with as much as 14,000 tons of coal] “Dominion [the coal company] blamed an extra-dry shipment of coal combined with high winds. The company said it would no longer unload coal in winds over 15 miles per hour.” This last precaution does not seen to be an option at the Dos Republicas mine as they have stated that once the mine goes into full operation, it will run virtually 24/7.
All the coal extracted from this mine will be shipped to Mexico via the Union Pacific Railroad through Eagle Pass. On average, one 130 car train will pass through town almost every day and each car will carry about 110 tons of coal. It is this part of the operation which presents the greatest dust hazard to the community and to schools near the railroad tracks, such as Seco Mines, Liberty, Glass and Kennedy Hall. On windy days, coal dust is liable to be blown off the top layer of coal in the railcars into the city.
Again, there are steps that Dos Republicas could take to limit this problem, but their permit application makes no mention of any of them. Dos Republicas is apparently very worried about this aspect of the operation since they have asked the Railroad Commission to “prohibit any mention [of] the transport of coal once it leaves the Mine Permit Boundary” during the hearing process because “this information is highly prejudicial.” The Railroad Commission hearing examiner has granted this request.
So, what is so bad about coal dust? The U.S. Occupational Safety and Health Administration (OSHA) states the in humans “Coal dust causes pneumoconiosis, bronchitis and emphysema in exposed workers. Coal dust causes coal workers’ pneumoconiosis (CWP).” “CWP is characterized by lesions [in the lungs]” and “may be associated with decrements in ventilatory [breathing] capacity and premature death.” “The disease may progress after the cessation of exposure” and “because occupational exposure to coal dust may cause diseases with prolonged latent periods, the need for medical surveillance may extend well beyond termination of employment.” Of course, those most at risk from the coal dust are the mine workers, However, the constant (almost daily) exposure of Seco Mines, Deer Run, Siesta Acres and Eagle Pass residents to coal dust escaping from the mine and off of railcars over a long period of time may create similar dangers for the general public. Dos Republicas has stated that the projected total life of the mine will be 18-20 years and that there are about 18 years of coal reserves in the area of the mine and adjacent leased lands. OSHA also states that in experimental animals, “coal dust is a tumorigenic [cancer-causing] agent.”
As was noted earlier, the coal in this area is high in ash and silica (silicon dioxide) content. Inhaled crystalline silica is, according to the U.S. Department of Health and Human Services (HHS), a “known to be a human carcinogen.” The U.S. Mine Safety and Health Administration has stated that in a 1995 study, they had identified “eight cases of silicosis among surface coal drillers and miners in Pennsylvania. Silicosis is an incurable and often disabling lung disease caused by silica dust. At mine sites, silica is generated during the drilling and crushing of rock and loading of mined materials.” Again, those most at risk are the mine workers. However, HHS also states that “residents near quarries and sand and gravel operations potentially are exposed to respirable crystalline silica.” The smaller the silica particles, the deeper into the lungs they penetrate and the more damage they cause. Respirable, or inhaled silica, is generally too small to be seen with the human eye.
We must stop the mine now, before it gets started and endangers our health and quality of life. Accordingly, the Maverick County Environmental and Public Health Association is currently circulating petitions in the form of a letter to the Railroad Commission, asking them to deny Dos Republicas a permit to operate the mine.
The hearing on this permit starts January 30. We would like to ask the people of Maverick County to sign this letter when presented an opportunity to do so. We have already collected about 3000 and need as many as possible to demonstrate to the Railroad Commission the depth of opposition in the community to the mine. Since the average citizen will be unable to attend hearings in Austin, this is the only way to have his or her voice heard by State Government and the only way we have to influence the outcome of this hearing. If interested in obtaining a copy of this letter, please contact George Baxter at (830) 773-6480 or Diana Sanchez at (830) 776-9661.