Synfuel: A Marine Transportation Risk Assessment

Abstract

ABSTRACT Coal synthetic fuels have attractive tax incentives. The primary consumers of the coal synthetic fuels (synfuel) are power plants and coke plants. Some of these synfuels consist of approximately 99% coal and 1% oil emulsion. Unfortunately, these synfuels produce sheens in the marine environment when accidentally released. The sheens prompt a Coast Guard response with pollution fines and costly mitigation efforts. There are no current regulatory requirements for the marine transportation of synfuel. Treating the synfuels as an oil product from a marine transportation perspective would be cost prohibitive; treating the synfuels as coal may not be conducive to the marine environment; somewhere between the two extremes lies an economically, environment-friendly solution. In the absence of regulatory guidance, the Coast Guard initiated a twoday risk assessment to evaluate the risks of synfuel to the marine environment. The risk assessment focused on the marine transportation related (MTR) processes of loading, unloading, fleeting and transporting synfuel. Standards of Care were developed by a 25-member workgroup of industry representatives and regulators. The Standards of Care will be voluntarily selfimposed by industry to prevent and respond to releases of synfuels, which sheen in the marine environment. Those companies not adhering to the Standards of Care will receive little or no consideration from Coast Guard Captains Of The Port when violations of the Clean Water Act are investigated.