Marine Fueling Safety Is Everybody's Business

Fire safety expert William M. Shaughnessy explains what boaters and facility owners need to know so they don’t get blown out of the water.

The growing popularity of recreational boating in the US, with nearly 30 percent of Americans participating today, is raising the attention level for properly designing, installing and operating marine fueling systems. The risks are multiplied because of the special circumstances involved, such as fires, explosions and water contamination.

Fires and explosions can destroy not only the fueling facility, but also some very expensive water craft. Still worse, there is the very real danger of serious injury and death to employees and customers. Such disasters, along with leaks and spills that can occur otherwise, can also cause water contamination that leads to overwhelming clean-up costs. Preventing such events or mitigating their effects requires close attention to the proper design and installation of tanks, piping, dispensers and other components of the fueling system. Also, it is essential that station operators and boaters work hand-in-hand to maintain a safe facility. Safety from fire, explosion and environmental hazards associated with fueling of marine craft must be constantly monitored.

Accidents waiting to happen
Poorly constructed or improperly managed marine fueling stations provide all of the elements needed for a major fire, explosion or product release into the water system. The following examples capture some of the “sad but true” conditions at some marine fueling operations that I have seen or heard about over the years.

• At Marina #1, a boat eases into position and is tied to the fuel dock to take on gasoline. The inexperienced captain opens the fuel nozzle and dispenses gasoline into the fishing pole holder instead of the gas tank filler, thus covering the deck and hot engine compartment with gasoline. Unobserved by anyone else and wanting to hide his embarrassment, he quickly redirects the nozzle to the boat’s filler neck. A static charge jumps from the fuel nozzle to the fuel filler neck in the presence of explosive gasoline vapors. I’ll leave the rest for you to imagine.
• At Marina #2, a relatively large boat entering its assigned slip lurches forward and slams into the pier. The boat smashes open an electrical conduit and splits the exposed fuel pipe that runs from the fuel dock to the shore. Sparks meet spewing liquid. Again, you can complete the story.
• At Marina #3, a small fiberglass boat is docked at a pier. The crew is enjoying cocktails in the hot afternoon sun. A cooking fire breaks out onboard. Roaring flames quickly spread. Caustic black smoke from melting fiberglass fills the air. The fire spreads to adjacent boats and the pier. People in boats jump into the water. People on the dock panic and flee for shore.

Fire department personnel are on the dock, hurrying toward the burning boats. Fleeing boaters meet head-on with the firefighters, who are dressed in boots, helmets, and heavy coats. They carry air packs and lengths of fire hose. The dock is narrow and congested. Pandemonium! The prospects of this story ending without major damages and lost lives are worsened by the fact that the fuel pipe is attached to the burning pier, along with the shore electrical power.

• At Marina #4, the sun has been beating down on the pipe running from the dispenser on the dock to the shore. A boater begins fueling his boat. The fuel system is pressurized. When the cold fuel from the underground storage tank enters the warm piping, the fuel expands rapidly beyond the operating pressure of the piping system. A component of the piping system ruptures suddenly, spewing atomized fuel through an ignition source. Is there a fire or explosion? Does the system shut down before it’s too late to prevent a disaster?

The above scenarios are just some of the ways that fires, explosions and environmentally damaging releases can occur at marine fueling stations. The potential for these types of incidents must be carefully considered in the design, installation and operation of a marine fueling facility. In addition to the risks associated with dispensing fuel under the normal conditions of a land-based automotive fueling facility, fuel dispensing operations on the water pose several special, difficult risks not normally present elsewhere. In other words, the basics of handling flammable and combustible liquids remain much the same—it’s the dispensing environment that poses different challenges.

Help is here
Today’s marine fueling facility design, installation and operating codes and standards have benefited significantly from past experience. Organizations concerned with safety have incorporated a consensus of past experience with current industry technology to provide meaningful standards for guiding marine fueling facility owners.

Adherence to the standards effectively reduces the risks of accidents and protects against the loss of life and property during fuel transfer. The following standards contain provisions applicable to marine fueling facilities:

• NFPA 70, National Electrical Code, Article 555, Marinas and Boatyards
• NFPA 30, Flammable and Combustible Liquids Code
• NFPA 30A, Automotive and Marine Service Station Code
• NFPA 10, Standards for Portable Fire Extinguishers
• NFPA 302, Pleasure and Commercial Motor Craft
• NFPA 303, Marinas and Boatyards
• NFPA 77, Recommended Practice on Static Electricity • API 2003, Protection Against Ignition Arising out of Static, Lightning, and Stray Currents
• 33 USC 1321 (1986) Federal Water Pollution Control Act (FWPCA)
• 40 CFR 300, National Oil and Hazardous Substances Pollution Contingency Plan (NCP)

Modern marine service station fueling standards are under continual review and revision. The standards offer facility operators some leeway for choosing alternatives that provide an intended level of safety and protection. Many of these standards have been adopted by local legislative bodies for use by authorities having jurisdiction (AHJs). The standards provide a common-sense, practical approach to marine fueling facilities and operations. Facility operators who know and follow the standards are well on their way to creating a safe marine fueling program.

Marine fueling facilities are, in actuality, attended self-service stations located on the water. As such, they are much like, and must conform to many of the same rules as, attended automotive self-service stations insofar as land-based fuel storage, corrosion protection, remote pumps, leak detection and dispenser design are concerned. The primary differences between automotive and marine fueling facilities arise at the point where the piping carrying the fuel extends from the shore out over the water.

Dealing with gravity
A concern I always have when I view a marine fueling site is the elevation of the storage tanks in relation to the dispenser nozzles. If aboveground tanks (ASTs) or underground tanks (USTs) are at a higher elevation than the dispenser nozzles, a gravity head will form after the system is pressurized. In a system assumed to be shut down, this may lead to loss of product, either accidentally through pipe line leaks or by theft. Even with the pumps deactivated, a leak-free pressurized system will siphon when the nozzle is opened if the piping is full of fuel.

Where the tank is at an elevation that produces a gravity head on the dispensing unit, a device (such as a normally closed solenoid valve designed to open and close with the operation of the pump motor) should be installed to prevent gravity-discharge flow into the dispenser piping when the dispenser is not in use.

Photo 1: Shut-off valves and gravity valves installed between onshore pipes and flexible hose

These normally closed gravity valves should be: (1) installed downstream of the tank outlet block valve, at a point where the piping extends from the shore out over the water; (2) adjusted so that liquid cannot flow by gravity from the tank to the dispenser in the event of a failure of the piping or hose when the dispenser is not in use; and (3) equipped with a pressure-relieving device that will relieve any pressure generated by thermal expansion of the contained liquid in the piping back to the storage tank.

Thermal blocking of the pipeline occurs when contained liquid expands because of solar heat. If the resulting pressure, measured as high as 300 psi, is not relieved, it can rise above the rated operating pressure of the system and cause a product leak.

Gravity valves may be conveniently inserted into each fuel pipe at the point where the piping extends over the water. Emergency shut-off valves are also located at these locations. Photo 1 shows gravity valves and emergency shut-off valves for diesel fuel and gasoline lines just before they extend out over the water.

Tank location options—Storage tanks located onshore (including on piers of solid landfill) may be either underground or aboveground. Delivery of product to such tanks by direct piping from aboveground bulk storage tanks is dangerous and should not be done because of the risk of overfills and leaks.

Where an onshore location would require excessively long supply lines to the dispensers, tanks may be located on the pier, provided that: (1) the aggregate volume of stored product is not excessive; (2) the standards on spacing, diking, piping and electrical classification are followed; and (3) the authority having jurisdiction (AHJ) gives approval. The decision or approval to place tanks on the pier requires careful judgment. Each system must be evaluated on its own merits based on good engineering practice and the AHJ. Consideration must be given to safety guidelines and the potential results of a failure in the system.

Piping system worries
At marine fueling facilities, the piping system (pipes, valves and fittings) are exposed to stress and strain from many sources, including: physical impact, settlement, corrosion, vibration, expansion, contraction, stray electrical currents, static electricity, transient sources of ignition, water current and tidal forces. Special study must be given to metal piping, which is subject to corrosive influences of salt water.

Piping systems, therefore, require special protective features. For one thing, a means should be provided to assure flexibility of piping in event of excessive pier motion. Flexible piping and swing joints designed to withstand the stresses will reduce the incidence of system failure, product release and resulting fires and explosions. Piping installed beneath piers or within protective pier chases provides additional protection from the impacts of errant boat traffic, as well as from fire if one should occur.

Lengths of oil-resistant flexible hose may be used between the onshore piping and the piping on the floating structure, and between sections of floating structures, to accommodate changes in water level. At a minimum, at least two readily accessible valves to shut off, or control, the flow of fuel should be installed in each pipeline: one at or near the approach to the pier, and a second within four feet from the base of the dispenser unit (Photo 2).

Photo 2: Fuel shut-off valve piped between dispenser and hose reel

Additional shut-off control valves should be at the shore end of each piping section where flexible hose is attached (Photo 1). The purpose of these valves is to easily compartmentalize or isolate fuel within the pipeline in the event of emergency, damage or repair.

Marine fuel piping systems on piers or wharves longer than 200 feet should be equipped with a sufficient number of additional shut-off control valves to control the flow of fuel in case of emergency on the fuel dock. The location of these shut-off control devices should be familiar to the fueling facility operations supervisor. All such controls should be marked “EMERGENCY FUEL SHUT OFF” in two-inch red block capital letters and be accessible at all times.

Pipe, valves, faucets, fittings and other pressure-containing parts of marine fuel, piping systems should exhibit rapid-rise, high-temperature and impact resistance. They should meet material specifications as well as pressure and temperature limitations. ANSI B31.4, Petroleum Refinery Piping Standard, provides this guidance.

Nodular iron should conform to the American Society for Testing and Materials (ASTM) A395, Ferric Ductile Iron Pressure Retaining Castings for Use at Elevated Temperatures. Flexible piping used to provide flexible connections should be listed or labeled by a third-party nationally recognized testing laboratory, certifying to the product’s suitability for its intended use.

Photo 3: Isolating the fueling dock from other areas of the marina helps minimize potential damages from fires

Dispensers, hoses and nozzles
Marine service station dispensers should be located so as to minimize exposure to all other areas of the marina operations, including boat slips (see Photo 3). Where tide and weather conditions permit, all fuel handling should be outside the main boat berthing area. No boats should be tied to the fuel dock except for fueling. The fueling area should be located so that, in case of fire aboard a boat alongside of it, the danger to other boats will be minimal.

Marine fuel hose should be listed for its intended use. If lengths over 18 feet are necessary, the hose must be protected from damage. A retractable hose reel positioned next to the dispenser takes care of this (see photo on top).

Specifications of the National Institute of Standards and Technology Handbook 44 (1998), the weights-and-measures law of the land, require dispenser hose lengths to be as short as practical and not to exceed 50 feet measured from the metering unit.

Dispensing nozzles without latch-open devices, but with automatic closing devices, should be used. The absence of a latch-open device forces the operator to maintain control over self-service dispensing. This self-service aspect of fueling needs to be monitored. The fueling supervisor must use care to ensure that the operator does not jerry-rig the nozzle to hold it open.

Before the flow of fuel is started, the metal nozzle should be placed in contact with the boat’s fuel fill neck. This provides a bond or conductor that relaxes differences in electrical potential between each metallic or metallic-plated component of the boat fuel system and the shore-based dispensing system in contact with the fuel. So, touching the nozzle to the boat’s fill neck reduces the chance of a static spark occurring within the explosive atmosphere at the fill neck.

Photo 4: Electrical emergency fuel shut-off and standpipe connection

Electrical system precautions
The electrical components at a marine fueling station must be installed by a qualified electrician, in accordance with NFPA 70, National Electrical Code (NEC) provisions applicable to wet, damp and hazardous locations.

Emergency electrical shut-off switches should be located on each wharf. They should be clearly identified and readily accessible in case of fire or physical damage at any dispensing unit. The switches should be interlocked so that tripping either one will shut off power to all pump motors in the system. Resetting should be possible only from a master switch. A sign stating “EMERGENCY ELECTRICAL FUEL SHUTOFF” in two-inch red block capital letters should identify each switch (Photo 4).

Electrical wiring for the dispenser, onshore power and lighting should be installed on the side of the wharf opposite from the fuel piping system. This reduces the risk involved in mixing an ignition source with flammable vapor.

Where excessive stray currents are encountered on the shore, the piping going out from the shore (with Class I and Class II liquids) must be electrically isolated from the shore piping. This is necessary because shore-based stray currents can be transmitted through conductive hose to the boat’s fuel tank fill opening, which is often grounded to the boat’s hull. Without the required isolation, sparks at the fill opening are possible.

Isolation is accomplished by placing bonding and grounding connections on the shore side of the pipelines, approximately where the piping extends over the water. An isolating bushing is installed in the pipe line between the land and over-water piping. Isolating the piping separates the boat being refueled from possible stray currents available to buried piping. Placing a grounding rod at this separation point and bonding the over-the-water piping reduces the potential for static differences between the boat’s fuel fill piping and the fuel system piping.

Keeping things shipshape
Materials should not be placed on a pier so as to obstruct access to fire-fighting equipment or important piping system control valves. Where the pier is accessible to vehicular traffic, an unobstructed roadway from the fueling area to the shore end of the wharf must be maintained for access by fire-fighting apparatus.

Smoking materials, including matches and lighters, and other sources of ignition must not be allowed within 20 feet of areas used for (1) fueling, (2) servicing fuel systems for internal combustion engines or (3) receiving or dispensing Class I liquids. Conspicuous and legible signs prohibiting smoking should be posted within sight of customers being served. The motors of all equipment being fueled, as well as cooking and electrical appliances, must be shut off during the fueling operation, with the exception of emergency generators, pumps and other items essential to continuing operation.

Each marine service station should maintain one or more listed fire extinguishers having a minimum classification of 40-B:C, and located so that an extinguisher will be within 100 feet of each pump, dispenser and pier-mounted liquid storage tank.

Piers that extend more than 500 feet from the shore need to have a Class III standpipe installed in accordance with NFPA 14, Standard for the Installation of Standpipe and Hose Systems (Photo 4). The standpipe system and related fire department connections should be installed, tested and re-tested at appropriate intervals to ensure operation. In addition, portable fire extinguishers used as first-aid fire appliances should be provided within 75 feet of areas requiring fire protection.

Photo 5: Fuel line supports under a gangway between the shore and the fuel dock

Watch what they’re doing
In the marina environment, where the forces of nature already raise the risks involved in fueling operations to a level higher than other places, another element adds even more risks to the equation: the boating public.

Boaters are out for fun. They look at a dock as a place to keep their prized watercraft—not as housing for a fuel piping system. They may not be focused on the hazards of refueling nor on the contents of the pipes and hoses they may encounter under, alongside or on top of the piers or support floats (Photo 5). If they were, you would never see a boat tied-up to the fuel piping, a charcoal grill flaming in the wind on a pier that houses fuel piping, shore electrical power cords secured in place around fuel pipes or similar haphazard practices.

Another added-risk factor is that, unlike automobile drivers, pleasure boat operators generally are not required to be trained or licensed. Many are inexperienced; some are even taking their first turn at the helm. Following good safety rules around a fueling facility is probably not foremost in their minds.

No fuel should be dispensed to a boat unless a competent person supervises the entire episode. Marine service stations should have an attendant or fueling-operation supervisor on duty whenever the station is open for business. That person should be familiar with the fueling equipment, boats and the hazards inherent in dispensing fuel. He or she should know how the dispensing system and the emer- gency shut-off controls work.

Fueling should never be undertaken at night except under well-lighted conditions. No construction, main- tenance, repair or reconditioning work involving the use of open flames or arcs or spark-producing devices should be performed at any fueling facility.

Prior to the fueling of any boat, the fueling supervisor should make certain that the vessel is properly moored and that all connections are made. No Class I flammable liquid should be delivered to any vessel having its tanks located below deck unless each tank is equipped with a separate fill pipe—the receiving end of which must be securely connected to a deck plate and fitted with a screw cap.

The fill pipes of vessels receiving Class II or Class IIIA combustible liquids may be connected to a manifold fuel-fill system that extends into each separate tank. Each tank must be provided with a suitable vent pipe that extends from the tank to the outside of the coaming or enclosed rails so that the vapors will dissipate outboard.

During fueling, the attendant should always be within 15 feet of the dispensing component and emergency shut-off controls. The attendant should also maintain a clear, unobstructed view of the boat’s fuel filler neck and the system’s emergency shut-off mechanism. Smoking must be forbidden on board the boat or vessel and on the dispensing site.

The boat operator must communicate with the fueling supervisor relative to the fuel capacity of the boat and the quantity being requested. Tanks should not be completely filled. A minimum of two percent of tank space is needed for expansion. The space allowance should be six percent if the fuel being taken aboard is at a temperature of 32 degrees F or below.

No delivery of any Class I or Class II liquid should be made into a portable container unless the container is constructed of metal or is approved by the AHJ, has a tight closure, and is fitted with a spout or designed so that the contents can be dispensed without spilling. Portable containers of 12-gallon capacity or less should not be filled while they are in or on a marine craft.

No person should be allowed to pump, discharge, deposit, throw or spill or cause to be pumped, discharged, deposited, thrown or spilled into the water any crude petroleum or its products or any other flammable or combustible liquid, or any bilge water, or any water or any sewage containing any of the said substances.

The Federal Water Pollution Act prohibits discharges of harmful quantities of petroleum products into US navigable waters or adjoining shorelines. Harmful quantities of petroleum products have been defined by the Environmental Protection Agency (EPA) as those which violate applicable water quality standards or cause a film or sheen on the surface of the water, or cause a sludge or emulsion to be deposited beneath the surface of the water or on adjoining shorelines.

The penalty for illegal discharges is a civil penalty of up to $125,000 against the owner, operator or person in charge of the marina. The owner or operator of the source of a discharge is also liable for all removal costs, as well as claims of loss or injury by third parties.

Photo 6: Safety reminders posted at the end of this fueling dock are clearly visible to anyone using the facility

The captain’s charges
Boat owners and operators are charged with some grave responsibilities for protecting themselves, their passengers and others from the dangers involved with flammable and combustible liquids. For example, before refueling the boat, the owner/operator should ensure that:

• The boat’s fuel tanks are properly vented to dissipate fumes to the atmosphere outside of the boat’s hull (outside the coaming rail).
• The boat’s fuel system is liquid and vapor tight with respect to hull interiors.
• The fuel system, including the electrical bonding and grounding system, has been installed and maintained in compliance with the boat manufacturer’s specifications. • The attendant or other person handling the dispenser has been told how much the boat’s fuel tanks will hold and how much is to be dispensed.

There are many other things that boat operators and marine fueling station attendants should know and do to ensure a safe fueling episode. Their responsibilities cannot be clearly separated and, in many ways, are one and the same. Stark reminders of important safety procedures need to be posted in prominent places so that they can be seen by all people present in the fueling area.

Signing for safety
The conspicuously posted safety reminders (Photo 6) should be printed in two-inch red block capital letters on a white background. Following are some examples of what the signs should say.

Before Fueling:
• Stop all engines and auxiliaries.
• Shut off all electricity, open flames and heat sources. • Check all bilges for fuel vapor.
• Extinguish all smoking materials.
• Close access fittings and openings to prevent fuel vapor from entering enclosed spaces.

During Fueling:
• Maintain nozzle contact with fill pipe.
• Wipe up spills immediately.
• Avoid overfilling.
• Fuel filling nozzle must be attended at all times.

After Fueling:
• Inspect bilge for leakage and fuel odors.
• Ventilate until odors are removed.

If Class I flammable liquids are to be delivered, the signs at the fueling site should instruct the vessel operator to keep the entire vessel open and the bilge blowers turned on and allowed to run for at least five minutes before starting any engines or lighting galley fires. If bilge blowers are not available, an additional five minutes of ventng is required to allow the dispensation of explosive vapors that have entered the interior of the boat’s hull.

When the summer ends and storage begins, or when the boat is brought ashore for repairs, the marina service station operator must continue to stay one step ahead of flammable hazards. Vessels in storage may still contain fuel that is subject to thermal considerations and leaks, which build up explosive vapor within their hulls. It is not uncommon for stored vessels to ignite when sources of ignition present themselves.

Consult your local enforcer
With this article, I have tried to provide useful information on the risks involved at marine fueling facilities and their related design, installation and operating standards. For the most part, what I have given you will be applicable in most areas.

However, if you are about to build or upgrade a marine service station, you need to consult the appropriate building and fire code officials as early as possible in the planning stages to determine if code or safety conflicts exist. Many building code officials are willing to work with owners, architects and engineers and will consider alternative construction methods if a reasonable or equivalent level of life and property protection is proposed. The evaluation of existing conditions should include a review of all safety-related requirements to determine if and where a facility or plan is deficient with respect to applicable codes.