Section 1: Preventing Spills at the Source
Prevention is key when it comes to spills and leaks of dangerous substances. There are many things you can do to prevent oil and gas from entering into the environment. This Section profiles the best management practices centered on keeping oil and gas out of the water at your marina.
By the end of this section, you should be able to:
- Understand the importance of safely storing, using and transferring oil and oil-based products.
- Describe several ways you can eliminate or reduce fuel spills and leaks.
- Educate employees and boaters about smart fueling and spill-prevention techniques.
- List equipment, practices and services you can use to help keep petroleum and fuel out of the water at your marina.
Best Management Practices
- Install and Protect Petroleum Storage Tanks Properly
- Avoid Waves and Wakes
- Install Environmental Controls at the Pump
- Advocate use of Oil-Absorbent Materials
- Supervise Fueling
- Promote Installation of Fuel/Air Separators
- Maintain Fuel Transfer Equipment
- Minimize Spills and Leaks from Machinery
- Offer Spill-Proof Oil Changes
- Provide an Oil-Water Separator
Install and Protect Petroleum Storage Tanks Properly
Fuel storage tanks at marinas typically hold from 1,000 to 10,000 gallons of fuel; if a tank were to rupture, the consequences could be devastating. Even if the tank system leaks or drips, the impact to the environment can be significant and expensive to remediate.
Aboveground storage tanks (ASTs) and underground storage tanks (USTs) are varied and complex and must be installed by a certified installer. Likewise, these tanks must be repaired and closed by state-certified personnel.
Operator training is required. Inspections of the storage tanks should be performed at least every three years, but are usually conducted annually. Although the day-to-day operation of fuel storage systems is quite automated, you must remain diligent to prevent any release to the environment — whether it is a catastrophic release or a drip.
General Tank Design , Monitoring and Inspection
- National Fire Protection Association guidelines on Storage Tanks (Part 3, Chapter 11 of NFPA 30A) address the storage and handling of flammable and combustible liquids (FL/CL) at marine fueling locations.
- Be aware that the municipality in which the tank is located may have additional requirements for the siting of the tank. Also, check with your state fire marshal and local fire department.
- Properly label tanks.
- Locate tanks at least 10 feet back from the ordinary high water mark of a navigable body of water.
- Each operating day, measure inventory. Record the amount of fuel dispensed and the amount remaining in the tank.
- Record deliveries. Take a daily reading of the amount of fuel delivered and pumped.
- Inspect ASTs and piping regularly for drips or leaks, and monitor USTs at least every 30 days for leaks.
Aboveground Storage Tanks (ASTs)
- Obtain the necessary permits and meet all requirements (e.g., labeling barriers, etc.) of the fire code for spill prevention and for fuel containment to operate a commercial Aboveground Storage Tank (AST) containing flammable or combustible liquids.
- Use a double-walled tank. (Single-walled tanks may be illegal in your state.)
- Place all piping connections to the tank above the normal maximum liquid level.
- Provide means to prevent the release of liquid from the tank by siphon flow.
- Provide means for determining the level of the liquid in the tank. This should be accessible to the delivery operator.
- Provide means to prevent overfilling by sounding an alarm when the liquid level in the tank reaches 90 percent of capacity and by automatically stopping delivery of liquid to the tank when the liquid level in the tank reaches 95 percent of capacity. These provisions must not restrict or interfere with the proper functioning of the normal or emergency vent.
- Space adjacent tanks more than 3 feet (0.9 m) apart to reduce fire hazards (Source: OSHA guidelines 29 CFR 1926.152(i)(2)(ii)(A)). Also, provide adequate space between stored boats or other structures.
- Install appropriate barriers (e.g., guard posts) to protect tanks and dispensing systems from damage.
- Where the interstitial space (space between the double walls of a tank) is enclosed, provide emergency venting.
- Install secondary containment system that would prevent accidental fuel releases if your fuel system does not have a double-walled configuration. Secondary containment must be sufficient to contain precipitation and the volume of the largest tank or container in each storage area. To meet these criteria, containment systems are typically designed to hold 110 percent of the volume of the largest tank or container in the area.
- Locate AST within a dike or over an impervious storage area with containment volumes equal to 1.1 times the capacity of the storage tank(s). Transfer areas where spills may occur must also be included.
- Open containment areas must be monitored. For fuel collected, contact your fuel supplier or waste oil hauler for disposal options.
- Cover the AST with a roof to prevent rainwater from filling the containment area, or provide a means for pumping out any accumulated oil/water mix.
- Uncontaminated rainwater collected by the dike can be allowed to evaporate.
- Stormwater collected in the diked area may be regulated. See: Stormwater Management Unit.
Underground Storage Tanks
- Meet the requirements of the Bureau of Underground Storage Tank Regulations (BUSTR) and Petroleum Underground Storage Tank Release Compensation Board (PUSTRCB) for monitoring and registration of your commercial Underground Storage Tank (UST) containing flammable or combustible liquids.
- Maintain current records of BUSTR registration and state-required paperwork. Registration renewal and fee is due each year (usually July 1).
- The U.S. Environmental Protection Agency (EPA) is proposing new UST requirements including operator training and secondary containment. Check for updates and act accordingly. Resources: State and Territory UST/LUST Program Status and Contacts (EPA), Underground Storage Tank Provisions of the Energy Policy Act of 2005 (EPA).
- Many states require financial assurance for UST operators to ensure that adequate funds are set aside to cover the costs associated with a leak or cleanup.
- Pay applicable fees each year.
- Make plans to cover required fees for the life of the tank and throughout any necessary clean-up process.
- Check state requirements for leak detection systems.
- Inspect tank release detection system for proper operation. Have current results available.
- Check piping release detection system for pressure piping; make sure electronic line lead detectors are working.
- Inspect overfill devices and alarm for proper operation. Be sure delivery person can hear or see alarm when activated.
- Check the shut-off valve on shore to halt, when necessary, the flow of fuel through pipeline from the oil storage facility to the fueling area.
- Ensure spill containment manhole is clean and empty. Remove any debris, inspect drop tube (metal pipe the runs from surface of fill to within six inches of bottom of tank that is intended to prevent static build-up.)
- Make sure fill and monitoring port covers and caps are tightly secured.
- Inspect piping and pump sumps for leaks. Remove debris and any water; dispose of it properly.
- Open dispenser and dispenser sumps to inspect all visible piping, fittings, and couplings for any sign of a leak. If any water or product is present, remove it and dispose of it properly. Remove debris.
- Inspect dispenser hoses, nozzles and breakaways for loose fittings, deterioration, obvious signs of leakage, and improper functioning.
- Inventory and inspect the emergency spill supplies.
- Inspect impressed current system (if applicable) for proper operation (bimonthly).
- Test mechanical line leak detectors at least once a year; use manufacturer’s recommendations.
- Annually test pressure piping using precision test or other approved method.
Avoid Waves and Wakes
Spillage around fueling areas is often caused by unanticipated movement of the boat and/or dock.
- Locate fuel docks in areas protected from wave action and boat wakes when constructing new or upgrading existing facilities. For safety reasons, all fueling stations should be accessible by boat without entering or passing through the main berthing area. Many fuel leaks are related to leaking fuel supply lines caused by chaffing, dock movement, fires and other accidents. Siting fuel docks must take into account many factors.
- Provide a stable platform for fueling personal watercraft to help drivers refuel without spilling. You may purchase prefabricated drive-on docks or modify an existing dock by cutting a v-shaped berth and covering it with outdoor carpeting. Consider placing the fueling area for personal watercraft at the end of the fuel pier to reduce conflict with larger boats.
Install Environmental Controls at the Pumps
- Remove fuel nozzle holding clips. The use of holding clips to keep fuel nozzles open is illegal at marina fuel docks (Michigan, Ohio and Wisconsin).
- Protect hoses (18 feet or longer) used for dispensing fuel. When not in use, hoses should be reeled, racked or otherwise protected from damage.
- Install automatic back pressure shutoff nozzles on fuel pump discharge hoses to automatically stop the flow of fuel into a boat’s fuel tank when sufficient reverse pressure is created.
- Turn down the pressure. Problems with backsplash and vent line overflow are often due to the high pressure flow of fuel from the pump. Ask your fuel company representative to set the delivery rate appropriately for the size of boats at your marina. For example, this may be a calibration of 10 gallons per minute if your marina caters to smaller boats.
- Consider installing fuel nozzles that redirect blow back into the vessel fuel tank or vapor control nozzles to capture fumes.
- Maintain a supply of oil-absorbent materials at the fuel dock to mop up spills on the dock and in the water. See below.
- Make alternative fuels, such as biodiesel, available. Biodiesel requires no retrofitting or engine modification. It is biodegradable, is less toxic than other fuels and has very low sulfur content. (High levels of sulfur found in crude oil can cause difficulties such as corrosion and air pollution.)
Advocate Use of Oil-Absorbent Materials
Oil-absorbent pads, booms and pillows absorb hydrocarbons and repel water. Depending upon the type, they may hold up to 25 times their weight in oil. These types of products are useful for capturing spills at the fuel dock, cleansing bilge water, and wiping up spills in engine maintenance areas.
There are a number of new twists on basic oil-absorbent materials. One variety of oil absorbent booms captures oil from the bilge and solidifies it into a hard rubber bumper. Other types contain microbes that digest the petroleum and convert the oil to carbon dioxide and water. Because the microbes take two to three weeks to digest a given input of oil, these products are mainly used to collect oil in bilges.
Another type of oil-absorbent product is a boom constructed of oil-absorbent polypropylene fabric that is filled with dehydrated microbes. These booms hold the petroleum in the fabric until it is digested by the microbes, minimizing threats associated with free-floating petroleum.
At Fuel Dock:
- Secure oil-absorbent material at the waterline of fuel docks to quickly capture small spills. Look for oil-absorbent booms that are sturdy enough to stand up to regular contact with the dock and boats. Some states may limit use of fixed absorbent curtain booms at fueling dock due to shading issues.
- Place plastic or nonferrous drip trays, lined with oil-absorbent material, beneath fuel connections at the dock to prevent fuel leakage from reaching the water.
- When filling small gas cans, place them inside drip pans lined with oil-absorbent material. Ensure that you are still grounding your container to dissipate static charge.
- Post instructions at the fuel dock, directing staff and patrons how to respond to a spill. Marina staff should immediately remove small drips of fuel from the dock and water with oil-absorbent material. Be sure to indicate the location of the absorbent materials and have well-marked spill kits in dock areas. Larger amounts of spilled fuel require a different response, including notifying local responders, evacuating the area, shutting down source (if possible), and eliminating any ignition sources. For details, see the Emergency Preparedness section of this unit.
- Make absorbent materials readily available. Distribute pads and bilge pillows to your customers.
- Require tenants to use oil-absorbent materials as part of your lease agreement.
- Make available and promote the use of oil absorbent materials during oil changes, fueling and in the bilge areas of all boats with inboard engines.
Remember, absorbent materials are only a first line of defense against a spill. For information on:
- Responding to a spill, see the Emergency Preparedness section of this unit.
- Disposal, see “Proper Disposal of Used Oil Spill Materials” in the Waste Management and Recycling Unit.
Implementing a fueling procedure will help you to comply with legal requirements and will reduce the likelihood of a spill.
For Marina Employees:
- Always have a trained employee at the fuel dock to oversee or assist with fueling.
- For employee training opportunities, see Section 2: Emergency Preparedness.
Video Learning: Fueling at the Gas Dock
- Train employees to:
- Observe fueling practices; make sure fuel is not accidentally put into the holding or water tank.
- Clarify what the boater is asking for. For example, as your employee passes the fuel nozzle to the boater, they should say: “This is gasoline. You asked for gasoline, right?”
- Hand boaters oil-absorbent pads with the fuel nozzle. Request that the boaters use them to capture backsplash and vent line overflow.
- Attach a container to the external vent fitting to collect overflow — some products attach to the hull with suction cups. A rubber seal on the container fits over the fuel vent allowing the overflow to enter the container.
- Listen to filler pipes to anticipate when tanks are nearly full. Instruct boaters to do the same.
- Dispose of absorbent pads according to state and local regulations. See “Proper Disposal of Used Oil Spill Materials” in Waste Management and Recycling Unit.
- Require boaters to stay with their craft during fueling.
- Require all passengers to disembark from gasoline-powered vessels before fueling.
- Instruct boaters to follow these safety precautions:
- Stop all engines and auxiliaries.
- Shut off all electricity, open flames, and heat sources.
- Extinguish all cigarettes, cigars, and pipes.
- Close all doors, hatches, and ports.
- Maintain nozzle contact with the fill pipe to prevent static spark.
- Use a slow filling rate at the beginning and end of fueling.
- Inspect the bilge after fueling for leakage or fuel odors.
- Turn on boat bilge blowers for several minutes before starting the engine. Ventilate until odors are gone.
- Remind boaters that gasoline vapors are heavier than air; they will settle in a boat’s lower areas.
- Encourage boaters to fill their fuel tanks just before leaving on a trip to reduce spillage due to thermal expansion and rocking, i.e., if the fuel is used before it warms up, it cannot spill overboard. If boaters prefer to refuel upon their return to port, encourage them to fill their tanks to no more than 90% of capacity. Also, leave expansion space in fuel tanks of boats going into storage.
- Encourage boaters to be aware of the amount of fuel they use for each trip; by knowing the amount of fuel per hour used, they can better estimate the amount needed at refueling, which will reduce chance of overspill.
- Encourage boaters to keep their engines well-tuned. Properly maintained engines use fuel and oil more efficiently and are less likely to leak and/or emit oil and vapor emissions into the environment. Mixing fuel for 2-cycle outboard engines according to the manufacturer’s specifications (usually 50:1 fuel to oil) can help prevent inefficient burning.
- Educate boaters about spill prevention:
- Post signage for boaters about clean boater fueling practices at your marina. For sample sign content, see the Fueling Checklist (courtesy of Eric Olsson, Washington Sea Grant):
- Check that boat is securely moored?
- Shut off boat engines and extinguish all open flames.
- Are there any other nearby ignition hazards?
- Ensure that there is a suitable fire extinguisher readily available?
- Is there sufficient lighting to safely fuel?
- Ensure you are able to read the fuel pump flow rate and gallon indicator from your filling position.
- Know how much fuel you need to fill tanks.
- Have absorbent pads available to catch fuel drips?
- Be prepared to catch fuel discharges from tank vents.
- Do not “top off” tanks!
- If possible, use a fuel catchment device on fuel tank vent.
- Locate the fuel pump emergency stop switch.
- Report all fuel spills: 1-800-424-8802 and the appropriate state agency… it’s the law.
- Print and photocopy tip sheets. Post one in your dock house and distribute copies to your customers. See petroleum control tip sheets at Resources and Tools: Tip Sheets.
- Post signage for boaters about clean boater fueling practices at your marina. For sample sign content, see the Fueling Checklist (courtesy of Eric Olsson, Washington Sea Grant):
Promote Installation of Fuel/Air Separators
- Promote the installation and use of fuel/air separators on air vents or tank stems of inboard fuel tanks to reduce the amount of fuel spilled into surface waters during fueling.
Often during fueling operations, fuel overflows from the air vent from the built-in fuel tank on a boat. Attachments for vent lines on fuel tanks, which act as fuel/air separators, are available commercially and are easily installed on most boats. These devices release air and vapor but contain fuel before it can overflow. Marinas can make these units available in their retail stores and post notices describing their spill prevention benefits and availability.
Maintain Fuel Transfer Equipment
- Inspect transfer equipment regularly and fix all leaks immediately.
- Maintain transfer equipment and hoses to ensure they are in good working order. Replace hoses, pipes, and tanks before they leak. Inspect hoses and hose connectors for frayed fabric or other damage that may lead to leaks.
- Maintain transfer equipment and hoses from the fuel delivery truck to ensure they are in good working order. Make sure good connections are made to the delivery nozzles (i.e., hard connect delivery nozzles).
- Hang nozzles vertically when not in use so that fuel remaining in hoses does not drain out.
Minimize Spills and Leaks from Machinery
- Perform regular maintenance on yard equipment (forklifts, tugs, trailers, hoists, etc.) and machinery, taking precautions to minimize oil spills and leaks.
- Take steps to prevent rainwater from coming into contact with or transporting oils and greases in runoff.
- Use non-water-soluble grease on equipment such as Travelifts, forklifts, cranes, and winches.
- Place fixed machinery that uses oil and gas on an impervious pad with containment berms to contain any spilled fluids. The secondary containment should mirror the controls recommended for aboveground storage tanks (containment capacity of 1.1 times the capacity of the machine’s fuel tank, and a containment area that allows oil-water mixes to be collected and disposed of appropriately).
- Place leak-proof drip pans or oil-absorbent pads beneath machinery. Empty the pans regularly, being careful to dispose of the material properly.
Note: Uncontaminated oil and antifreeze may be recycled.
Offer Spill-proof Oil Changes
- If you offer oil changes, implement appropriate procedures to collect, store and recycle or dispose of used oil and filters. Purchase a non-spill pump system to draw crankcase oils out through the dipstick tube. Use the system in the boat shop and rent it to boaters who perform their own oil changes.
- Provide (purchase or rent) an oil filter crusher to reduce the size of disposal waste. This device will crush the filter to approximately one-fifth its original size and will also remove the majority of excess oil for recycling. If you currently pay to dispose of your filters per drum, you will reduce disposal costs by placing five times more filters in each drum.
Case Study: In 2010, a Michigan marina collected 1,125 gallons of waste oil and approximately 750 used, crushed oil filters. In the past, the marina would have paid $1 per gallon to have the oil removed and an average of $2 per filter disposal cost. Now the marina works with a reclamation center willing to pay for the used oil and remove crushed filters free of charge. This approach reversed the flow of money – with the marina being paid for a service they previously paid for.
Then: Pay $1 disposal cost per gallon of oil, pay $2 for disposal of oil filter.
Now: Paid 17.5 cents per gallon and crushed filters removed free of charge.
Even accounting for startup costs, this arrangement will likely save you money.
- Slip a plastic bag over used oil filters before their removal to capture any drips. Hot drain the filter by punching a hole in the dome end and draining for 24 hours. Recycle the collected oil and the metal canister.
- Michigan: If not practical, then dispose of the filter in your regular trash. The State of Michigan does not consider used oil filters to be a hazardous waste if the filters are non-terne-plated and the used oil is removed from the filter using an approved method.
- Wisconsin: Oil filters were banned from Wisconsin landfills as of January 1, 2011 (WI Act 86, 2009).
- Ohio: If not practical, the filter may be disposed of in the municipal waste stream (OAC Rule 3745-51-04(B)(13)).
- Include information on appropriate handling of maintenance waste (e.g., used oil and filters) in contract language. Also, see Waste Management and Recycling Unit.
Provide an Oil/Water Separator
- Invest in a portable or stationary oil-water separator to draw contaminated water from bilges, capture hydrocarbons in a filter, and discharge clean water.
- Subcontract bilge cleaning services at your facility.