Marina Environmental
Management Plan
A Workbook for
Marinas, Boatyards
& Yacht Clubs in
New England
United States
Environmental Protection
Agency New England
EPA 901-B-05-001
July 2005
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New England Marina Environmental Management Plan Workbook
Table of Contents
Acknowledgements ii
Introduction 1
How to Use This Workbook 3
Some Useful References 4
Workbook Sections:
1. Establishing an Environmental Policy 6
2. Making Progress Over Time—Setting Goals 8
3. Assigning Responsibilities 14
4. Having Standard Operating Procedures 19
5. Keeping Track of Information 25
6. Maintaining Communication 31
7. Conducting Training 36
8. Maintaining the EMP—Monitoring and Taking Corrective Action 41
9. Creating a Master Calendar 46
10. Summary and Next Steps 49
Appendix:
A. Marina Checklist
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New England Marina Environmental Management Plan Workbook
Acknowledgements
This workbook was adapted for use by New England marinas, boatyards and yacht clubs—and based
largely on— "Documenting Your Environmental Management Plan: A Workbook for Small
Business," which was published by the U.S. EPA Small Business Division in 2002.
The project leader for the Marina EMP Workbook was Larry Wells, EPA Region 1, and the prime
consultant was Neil Ross Consultants including Neil Ross, Robin Shields, Lin Lee and Nancy Burke.
As part of EPA New England's marina initiative, thanks to these marina managers who provided
useful feedback on the contents of this workbook: William Munger (Owner, Conanicut Marina,
Jamestown, RI), and Chris Ruhling (General Manager, Brewer Yacht Yard At Cowesett, Warwick,
RI). In addition, thanks to the New England Regional Marina Networking Group for their assistance
in reviewing drafts of this document and providing input.
Disclaimer: This workbook discusses some of the most significant management actions a
marina can take to plan and track its environmental responsibilities and we hope that you find it
useful. Here, however, we need to list a few things that this workbook does not do. First, this
workbook should not be used as a method to identify applicable regulatory requirements
because: while it does refer to some federal regulations, it does not provide a detailed
description of any of the regulations which may apply to a marina; laws and regulations may
change over time; figuring out which regulations apply to a facility will depend upon the
particular processes and materials and chemicals used and finally, state and local requirements
can be different from federal requirements. Second, the Best Management Practices (BMP)
examples and technologies contained within this workbook, does not constitute any form of
endorsement or approval by the EPA of such technologies. Finally, EPA does not exercise
editorial control over the information contained in non-EPA guidance documents and web sites.
The references to these documents and web sites are provided for your convenience.
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New England Marina Environmental Management Plan Workbook
Introduction
Who is This Workbook For?
This workbook targets marina, boatyard and yacht club owners and managers committed to
improving environmental management in their boating business operations. For simplicity, the word
"marina" is used throughout this workbook to also mean "boatyard" and "yacht club."
By using this document, you will learn how to plan and implement controls and actions for effective
management of your environmental responsibilities. To accomplish this result, you will need to
obtain specific information regarding regulations and practices which are covered in other
documents. It is recommended that your state Clean Marina Guide, which this workbook is designed
to be utilized with, serve as your primary resource for obtaining detailed information (see page 4).
What is an Environmental Management Plan (EMP)?
An EMP is the action an organization is taking to determine how it affects the environment, comply
with regulations, keep track of environment management activities, and meet environmental goals
and targets. It also documents key elements of environmental management including the
environmental policy, responsibilities, applicable standard operating procedures and Best
Management Practices (BMP), record keeping, reports, communication, training, monitoring, and
corrective action. The EMP features the "Plan, Do, Check, Act" model for ongoing improvement.
PLAN
CHECK
Plan—Planning, including identifying environmental impacts and establishing environmental
goals
Do—Implementing, including employee training and establishing operational controls
Check—Checking, including auditing, monitoring and taking corrective action
Act—Reviewing, including progress reviews and taking action to make needed changes to the
EMP
Environmental management is easier if you have an EMP, because it will help you better track your
environmental management activities and implement them in a more organized and streamlined
manner. An EMP gives you a framework in which to:
Comply—Assist you in assessing compliance with environmental regulations
Improve—Allow you to identify opportunities for improvement and cost savings
Know—Decrease costly confusion for your employees by spelling out exactly what is expected
of them
What are the Benefits of Using an EMP?
Using an EMP allows you to realize both business and environmental benefits at your marina. Some
examples of EMP benefits include:
• Improved environmental performance
• Prevention of pollution and conservation of resources
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New England Marina Environmental Management Plan Workbook
• Reduced environmental risks
• Attracting new/improved customers
• Increased efficiency, more effective work procedures and reduced operational costs
• Enhanced employee moral and awareness of environmental issues
• Enhanced positive image with public and regulators
• Help in getting recognition for good practices, such as "Clean Marina" awards in states1 with
those programs
An EMP also provides you with a plan to oversee what is done—as well as when it's done and by
whom—to meet and go beyond all required environmental regulations.
Clean marinas are proving attractive to more responsible boating customers, may operate more
profitably, and can help protect the boating environment. Not every marina can realize all these
benefits, but most can come close.
An Important Note About This Workbook
Throughout this workbook you will find examples for a fictional "Salty Cove Marina" that describe typical
situations/problems and suggested actions/solutions that might apply to your marina. Of course, these
examples for the Salty Cove Marina do not anticipate all of the problems or issues that could arise at all
marinas; your marina may face different or additional issues.
Summary Description of the Salty Cove Marina:
Salty Cove Marina has 12 full-time employees with 75 dock slips, 12 moorings and on land storage for 200
boats. Located on the edge of a bay at the bottom of a watershed, the facility conducts boat maintenance and
repair, cleaning and fueling and has capacity for storing more than 1320 gallons of oil and gas above ground
and for storing more than 10,000 gallons of fuel underground. These operations contribute toward the marina
having potential sources of pollutants similar to those commonly found in many other marinas such as oil, gas,
boat sewage, pet waste, trash, toxic metals, solvents, antifreeze, and detergent. Also, due to the size of Salty
Cove Marina, most employees have multiple job assignments. For example, the Service manager's area of
responsibility includes the mechanic shop, paint shop, and carpentry.
Many federal, state and/or local regulations apply to Salty Cove Marina. While it is not within the scope of
this document to fully address all regulations, this document does partially refer to some of the federal or state
regulations that Salty Cove marina is required to meet in the following areas:
-Storm Water Management/The Clean Water Act (CWA)
-Hazardous Waste Management/The Resource Conservation and Recovery Act (RCRA)
-Spill Prevention Control and Countermeasure Planning (SPCC)/The Oil Pollution Act of 1990 (OPA)
-Hazardous Chemical Reporting/The Emergency Planning and Community Right to Know Laws (EPCRA)
-Air Quality Management/ The Clean Air Act (CAA)
-Pesticide Control/Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
-Construction Management/Rivers and Harbors Act of 1899 (and the CWA)
1Many states have clean marina programs which are typically voluntary incentive based recognition programs for establishing "clean
marinas". Under these efforts, marinas are encouraged to utilize state clean marina guides developed under the program and those
participating marinas that meet and go beyond compliance are recognized as "clean marinas". New England states with "Clean Marina
Programs" include Connecticut, Maine, and Massachusetts; New Hampshire and Rhode Island are in development.
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New England Marina Environmental Management Plan Workbook
How to Use This Workbook
1. Read This Workbook First
Before beginning an EMP, we recommend that you read through this workbook to get an overall
picture of the EMP process. Each section explains the recommended tasks you need to complete,
contains a worksheet to guide you through the steps, and provides an example of how that portion of
the EMP might look once completed.
2. Marina Environmental Team
You will find it helpful to appoint a clean marina team who works together to build the EMP. The
team should include, as appropriate, the facility owner, general manager and key marina staff. Assign
one reliable team member as the EMP coordinator.
3. Start With What You Have
For each section of the workbook:
1. Read the recommended tasks
2. Review the examples for Salty Cove Marina
3. Complete the recommended tasks using available resources, such as the worksheets provided,
marina records, staff and published environmental guides
Much of what you need to put together for an EMP is likely already in place at your business. In fact,
most marinas have already begun many parts of the environmental management process.
Use this workbook as a step-by-step approach to help better organize your marina's program to
manage environmental impacts. In making this effort, you will need to use several important
references published elsewhere, including publications with federal, state, and local laws and
regulations, (see "Some Useful References" on page 4) In particular, your state Clean Marina Guide
is a tool that can be used throughout the year to help you accomplish many of the tasks outlined in
this document.
4. Dedicate Time Needed
Completing this process takes time and dedication. However, if done well and with steady progress,
you will achieve the goal of improved environmental management for your marina. In determining
what schedule to work on your EMP, consider the amount and type of business activity taking place
at your facility throughout the year. For example, a good time to develop your marina EMP may be
in the winter season after haul out ends, and well before spring launch begins. Another example for
scheduling may be to assess your EMP in mid-August when all areas of the facility might be
operating.
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New England Marina Environmental Management Plan Workbook
Some Useful References
New England State Clean Marina Guides
Each of the coastal New England states has published guidelines for marina use. These documents
are very helpful and contain specific references to many state environmental laws and regulations. All
the publications also list numerous BMPs illustrating a range of choices for marina managers.
In particular, we suggest you use this workbook with the following state guidelines for marinas:
Connecticut: Connecticut Clean Marina Guidebook. 2002. Contact: Elke Sutt, Connecticut
Department of Environmental Protection, 79 Elm Street, Hartford, CT 06106, (860-424-3034),
Maine: Bright Work: A BMP Guide for Marinas 2003 Contact: Pamela Parker, Maine
Department of Environmental Protection, 17 State House Station, Augusta, ME 04333, (207-287-
7905), pamela.d. parker@maine.gov
Massachusetts: Massachusetts Clean Marina Guide 2001 Contact: Robin Lacey, Massachusetts
Office of Coastal Zone Management, 251 Causeway Street, Suite 900, Boston, MA 021 14, (617-
626-1220), robinJacey^statejnajjs
New Hampshire: Best Management Practices for New Hampshire Marinas. 2001. Contact: Sara
Johnson, New Hampshire Department of Environmental Services, Pollution Prevention Program,
29 Hazen Drive, Concord, NH 03301, (603-271-6460), www.des.nh.eov/nhppp/marinas.htm
Rhode Island: Environmental Guide for Marinas. 1994. Contact: Rhode Island Sea Grant Office,
University of Rhode Island, Narragansett Bay Campus, Narragansett, RI 02882, (401-874-6842)
For Vermont reference material contact Judy Mirro (802-241-3745).
Other Useful References
In addition to state guides, these other documents and websites may be helpful when developing your
EMP.
National Management Measures Guidance to Control Nonpoint Source Pollution from Marinas
and Recreational Boating. Nationwide guide for controlling pollution from boats and marina
operations on all inland and coastal water bodies; excellent source of practical clean marina
practices to consider adopting; recommended for every marina manager's bookshelf. This
national guide is used by all coastal states for developing their marina regulations, and is the
common foundation for all clean marina programs nationwide. 2001; EPA 84 1-B-0 1-005. Source:
Download from: http ://www. epa.gov/owow/nps/mm sp/. Order: 513-891-6561, ncepi wo@one. net
Practical Guide to Environmental Management for Small Businesses. Using the Environmental
Management System (EMS) approach, this publication helps small businesses organize their
environmental management responsibilities in a cost-effective way. The guide has been dubbed
"the on-ramp to EMS for small businesses," and praised for its practical approach. 2002; EPA-
233-K-01-01. Source: Download from http://www.smallbiz-enviroweb.org/ Order via telephone
800-368-5888.
Clean Marinas Clear Value. This EPA report gives case studies of 25 different marinas that
successfully use BMPs to help the business comply with environmental regulations and improve
business profits through cost savings, extra income or attracting more customers. 1996; EPA 841-
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New England Marina Environmental Management Plan Workbook
R-96-003. Source: Report can be downloaded from:
http://www.epa.gov/owow/nps/marinas/index.html.
Shipshape Shores and Waters: A Handbook for Marina Operators and Recreational Boaters.
This EPA summary guide is great reference booklet for marina use. 2003; EPA-841-B-03-001.
Source: Order via telephone 800-490-9198; E-mail: ncegimal@onejiet; download from:
U.S. Environmental Protection Agency Office of Solid Waste Regulations and Standards
Website- at: http://www.epa.gov/epaoswer/osw/laws-reg.htm
U.S. Environmental Protection Agency: The National Response Team's Integrated Contingency
Plan Guidance (One Plan)-at:
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New England Marina Environmental Management Plan Workbook
Section 1.
Establishing an Environmental Policy
Your marina should have an environmental policy as part of its business plan. An environmental
policy is a concise statement of a boating business's commitment to protect the environment, comply
with regulations and improve practices. It shows that managing environmental issues is a high
priority for your business, and it represents the basis upon which all aspects of the EMP are built.
The policy should begin with a statement of your business commitment to environmental
stewardship. This should include a commitment to preventing pollution and to continuously
improving environmental performance. Many businesses also add a provision about keeping
employees and community members safe and regularly trained. A sound environmental policy should
also make a commitment to comply with applicable laws, and to use applicable BMPs.
The environmental policy also states how the marina, boatyard or yacht club will live up to its plan. It
is important when putting the policy together to consider the stated goals and the level of resources
your business is willing to commit to achieve them.
Once established, the environmental policy will help communicate your business's environmental
management commitment to marina staff, customers, government officials and others.
Example 1: Salty Cove Marina2 Environmental Policy
The management and staff of Salty Cove Marina are committed to preserving and protecting the
quality of our bay areas environment. A clean environment is important for the success of our
business and for that future generations can also enjoy these precious resources.
In support of this commitment, we strive to conduct clean boating and marina practices at our marina
and will educate our staff, customers and guests on sound practices. Our overall goal is to be the Bay
areas business leader in protecting the environment. We will achieve this goal by using a team-
oriented management approach to help ensure responsible use of our air, land, and water resources.
To achieve this goal as a full service marina/boatyard business, Salty Cove Marina will meet or go
beyond compliance with all applicable federal, state and local environmental rules and regulations.
We endeavor to continually improve our environmental performance and to prevent pollution before
it is produced. All our marina employees are expected to support our environmental goals while
providing clean, affordable boating services that help keep boating good clean recreation.
(Signed) Salty Smith, Owner
(Date)
fj
"Salty Cove Marina" is a fictional example, not a real business, but may be similar to many marinas
in New England; of course, your marina may have different, or additional challenges.
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New England Marina Environmental Management Plan Workbook
Environmental Policy
Step 1: Key Word List
Think about the goals you want to achieve through your environmental policy. Brainstorm a list of
action words or very short phrases that reflect environmental impacts; then choose words or phrases
that reflect your marina's environmental commitment to its business, employees, customers and
community. Examples of action words include: reduce, improve, increase, preserve, protect, require,
request, commit, support, provide, educate, train, demonstrate, and lead the way.
Step 2: Statement
Create a concise one- or two-sentence statement using the list of action words and phrases above.
Step 3: Plan Methods
List how the marina is achieving, or plans to achieve, the commitment(s) expressed in the statement
above.
Step 4: Plan Statement
Use the list developed in step three to put together a statement of how the marina will fulfill its
environmental commitment(s).
Step 5: Fine-Tune Policy
Combine the statements developed in steps two and four and fine-tune them to form the complete
environmental policy. Consider asking key employees to help fine-tune your environmental policy.
Step 6: Approval
The marina owner, general manager or club commodore signs the final policy statement making it an
official commitment to protect the environment.
Step 7: Communication
The marina's environmental policy is communicated to all employees and is posted on bulletin
boards.
Step 8: Review
Periodically review your marina environmental policy to ensure it is relevant and current.
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New England Marina Environmental Management Plan Workbook
Section 2.
Making Progress Over Time: Setting Goals
A goal is a general statement expressing a desired outcome you wish to achieve through your
marina's EMP. Setting goals to improve environmental management connects the EMP to daily
business activities and helps assure overall commitment to your EMP. You should be able to
measure progress made for each of the goals you establish.
The U.S. EPA and the National Oceanographic & Atmospheric Administration (NOAA) have jointly
designated general pollution prevention goals3 for all marinas and boats.
These national goals are organized into broad categories that may apply to your marina:
• Stormwater runoff (controlling)
• Petroleum control
• Liquid material management
• Solid waste management
• Fish waste management
• Sewage facilities and maintenance
• Boat cleaning
• Boat operations
• Public education
For new marinas, or marinas planning major expansions, goal categories may include:
• Marina flushing
• Water quality assessment
• Habitat assessment
• Shoreline stabilization
• Stormwater runoff (designing for controls)
• Fueling station design
When you start setting goals, if your marina is not fully in compliance, first begin with the mandatory
compliance goals. Once compliance is achieved, you will then need to set focused and measurable
goals beyond compliance that will add the most value to the marina and boating environment.
Your goals should be realistic and fit within the marina's mission and overall business strategy. Your
goals should also inspire action by giving a clear vision of desired environmental performance.
Because the number of goals a small business can effectively tackle at once is limited, identify the
goals that are critical to the business's environmental performance and tackle those first.
If you need help in identifying goals, your state clean marina guide may be a useful source of
information. It is likely to contain comprehensive and specific information regarding applicable
regulations and desirable best management practices for your facility.
3 EPA and NOAA call these key national goals "marina management measures."
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New England Marina Environmental Management Plan Workbook
Note:
EPA has adopted policies designed to encourage greater compliance with environmental regulations and
laws. Two such policies, "Incentives for Self Policing, Discovery, Disclosure, Correction and Prevention of
Violations" (Audit Policy), and "policy on Compliance Incentives for Small Businesses" (Small Business
Policy), provide incentives to conduct environmental audits by substantially reducing or eliminating
penalties for companies that voluntarily discover, disclose, and expeditiously correct violations of
environmental law. For more information visit EPA's Audit and Small Business Web pages at :
|oy^
Your state may also have compliance incentive business policies. Please check with your state
environmental agency for further information.
Setting Goals
Use Worksheet 2a—Environmental Goals to Consider—to complete this section.
Step 1: Brainstorm Goal List
Identify marina practices that can cause harmful environmental impacts. Then review the
environmental regulations that apply to your marina. Brainstorm a list of possible goals to improve
environmental management and list them in the first column of Worksheet 2a. Don't worry about the
difficulty of achieving a goal or its relative importance at this point.
Step 2: Significance—Rate Your Goals as "Critical" or "Important"
Review the list of goals developed during step two and decide whether each goal is critical or
important. Indicate the goal's significance in the second column of Worksheet 2a. What is deemed
critical or important to one marina may not be so in other marinas.
In determining if a goal is critical or important, consider the following
Critical —Is the goal needed to comply with mandatory environmental regulations and/or
avoid bad publicity? Is it essential to marina business?
Important —Is this something the marina wants to do to improve environmental conditions?
Step 3: Difficulty—Determine Your Goals' Degree of Difficulty
For each goal, indicate in the third column of the worksheet the degree of difficulty involved with
achieving the goal. Consider the budget, number of staff, degree of effort and other resources needed
to achieve it.
In determining how difficult the goal is, consider the following
High —Does it require considerable time, material, capital costs, etc., to complete?
Average —Can it be accomplished with moderate effort and cost to complete?
Low —Is it easy to do?
Step 4: Goals—Select Three to Six Primary Goals
Select at least three to six primary goals to consider working on for the next several months to a year.
Critical goals should be the first priority. Once these areas are addressed, consider selecting goals that
have the biggest return for the invested effort.
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New England Marina Environmental Management Plan Workbook
Worksheet 2a—Environmental Goals to Consider
Primary Goals
Significance
Difficulty
Significance = Critical or
Important
Difficulty = High, Average, Low
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New England Marina Environmental Management Plan Workbook
Selecting Goals and Setting Targets
Step 1: Select Goals to Use
Use answers on Worksheet 2a—Environmental Goals to Consider, to complete Worksheet 2b—
Environmental Goals and Targets Plan. Use those primary goals to decide on the best way to
measure progress toward meeting that goal. It is helpful to keep it simple by using your marina's
environmental data that is already available, as long as it provides a meaningful measure.
Step 2: Set a Target
For each goal, decide how much improvement is desired and set a realistic target. Targets are
specific, shorter-term steps towards achieving a goal. When coupled with measurable targets,
meaningful goals become the driving force behind environmental performance improvement. Be sure
your goals have reasonable targets.
For example, your goal might be to reduce water usage. The specific target might be to reduce water
consumption by five percent. As a result of this goal and specific target, your annual water bill should
also decrease. The cost savings realized is another indicator of success.
Step 3: Create a Goals and Targets Plan. You should create and implement a management plan to
achieve each goal and target. For example, to achieve the goal of reducing water use and the specific
target of reducing water use by 5 percent, your management plan might require that all water hoses
use automatic shut-off nozzles and that all leaks in dock pipes be repaired.
Step 4: Assign Responsibility. Assign responsibility for gathering the information needed to
establish your baseline and to confirm whether your marina has met its target. Add the name or title
of the person responsible in the fourth column on Worksheet 2b.
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New England Marina Environmental Management Plan Workbook
Example 2: Environmental Goals and Targets Plan for Salty Cove Marina
Goal
Comply with all
environmental
regulations
Ensure that no
inappropriate waste
is disposed in the
dumpster.
Ensure all
employees are
aware of and
understand
environmental
policy
Reduce the use of
electricity
Target
Comply with all
environmental
regulations
No inappropriate
waste (oil, paint,
etc.) disposed in
the dumpster
Communicate
environmental
policy to all
employees
Reduce
electricity use by
5%
Management Action(s)
-Identify and list applicable
regulations; primary research
sources include the state
marina guidance document
-Develop a system to stay
current with new requirements
-Monitor dumpster weekly for
wastes that do not belong
-Update employee training on
waste management practices
-Create clearly designated and
marked areas for patrons to
leave acceptable wastes
-Educate patrons on use of site
disposal options and
unacceptable materials
-Present environmental
policies to employees
-Post environmental policy in
office, break rooms, and work
areas
Replace existing light bulbs
with Energy Star light bulbs in
all marina buildings and in
dock lights
Responsible
Person
General
Manager
Yard
Manager
Owner
Dockmaster
Timetable
Within 60
days
Within 90
days
Within 2
weeks
Within 60
days
Within 60
days
Within 6
months
Within 90
days
Within 90
Days
Within 45
days
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New England Marina Environmental Management Plan Workbook
Worksheet 2b—Environmental Goals and Targets Plan
Goal Target
Management Action(s)
Person Responsible
Timetable
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New England Marina Environmental Management Plan Workbook
Section 3.
Assigning Responsibilities
As part of an BMP, each employee must have clearly defined roles and responsibilities for the
environmental management activities they are assigned. This in turn will increase accountability
within the marina and ensure that environmental management activities are handled correctly.
Because every boating business is unique and site specific, each marina should determine what roles
and responsibilities are appropriate for the operation that will best achieve the stated goals.
Depending on the size and range of services offered at each marina, the key responsible person may
vary. No two marinas will have the exact same management organization or staffing.
For example, in a small marina, the owner may also be the general manager and have oversight,
hands-on responsibility for all activities and all staff. The owner of a large, full-service marina chain,
however, may have one or more general managers to control each facility. They then delegate key
environmental responsibilities to the safety officer, service manager, parts manager, yard manager,
dockmaster and/or maintenance manager, who in turn oversee their staff.
When assigning responsibility, you may also find it helpful to distinguish between critical
responsibilities—those of highest priority—and important responsibilities, those based on the amount
of time and work involved to implement the EMP.
Once defined, responsibilities must be formally communicated to each employee in their general job
description. Everyone should receive a copy of his or her specific job description, with a signed copy
placed in his or her personnel file. Doing this will help your staff understand their job responsibilities
and provide a method for evaluating employee performance during annual reviews. Make sure you
assign tasks so that the workload is shared and environmental management is a team effort within the
marina.
See Example 3, Environmental Responsibilities at Salty Cove Marina—and use Worksheet:
Assignment of Environmental Responsibilities.
Please note: To help ensure you identify all areas for assigning responsibility you can use your state
clean marina guidebook and other resources (see "Some Useful Resources" on page 4).
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Example 3: Environmental Responsibilities at Salty Cove Marina
*Position
Environmental Responsibilities
Designation*
Owner
Ensure compliance with all federal, state, and local laws and regulations.
Oversee environmental policy and Environmental Management Plan (BMP) and
Oversee environmental manual.
Serve as primary contact for regulatory inspectors.
Commit resources to achieve environmental goals.
Review audit results and progress on achieving goals and revise BMP as needed.
Update employees annually on environmental policy and goals.
Incorporate environmental procedures into customer contracts.
Critical
Critical
Critical
Critical
Important
Important
Important
Environmental
Coordinator
(can be owner,
general manager or
assigned staff)
Manage environmental responsibilities for the owner.
Oversee all employees and monitor their progress against management plan targets.
Prepare all manual changes and report in advance of due dates.
Conduct staff environmental training; regularly include environmental issues in
weekly staff meetings.
Maintain environmental permits and provide quarterly reports as needed
Report monthly or as needed to owner.
rrack and inform owner of changes to regulations affecting marinas.
Critical
Critical
Critical
Critical
Critical
Critical
Critical
All Employees
Attend training on and understand role in emergency action plan.
Attend training on and follow environmental SOPs and BMPs.
Participate in annual review of marina environmental policy and goals.
Critical
Critical
Critical
Dockmaster
Act as marina's Emergency Coordinator for emergency action plan.
Maintain emergency action plan and train employees on it.
Develop environmental SOPs and train employees on them.
Educate customers about marina's environmental policy and procedures and monitor
their activities for conformance.
Critical
Critical
Important
Important
Store Manager
Educate customers about environmental concerns related to product use, clean up,
equipment rental and maintenance activities.
Work with appropriate marina employees to evaluate effectiveness of
environmentally sound products.
Stock environmentally sound products that have proven to be effective.
Critical
Important
Important
Maintenance
Manager
Oversee management of wastes generated by employee activities and compile data on
waste management.
Produce quarterly waste data reports.
Perform sampling required by wastewater permit and submit reports to environmental
coordinator.
Monitor implementation of environmental SOPs and BMPs.
Critical
Critical
Critical
Important
* Some Salty Cove employees are responsible for more
than one position
* Designations may vary between different marinas.
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Maintenance
Technician
Groundskeeper
Fuel Dock
Attendant
Boatyard Manager
Mechanic Shop
Foreman
Paint Shop
Foreman
Carpentry
Foreman
Yard Crew,
Carpenters,
Mechanics,
Painters
Conduct weekly hazardous waste container inspections.
Perform quarterly visual inspections as required by stormwater permit.
Monitor oil/water separator for malfunction daily.
Monitor for improper disposal practices while emptying trash containers.
Utilize water conservation measures, integrated pest management and other means to
reduce use of chemical products on grounds, including chemical fertilizer.
Monitor fueling operations and dock activities for consistency with marina.
Environmental policy and procedures and report any problem to Dockmaster.
Watch for leaks or spills at fuel dock or during boat hauling.
Report all leaks to Dockmaster and initiate emergency action plan.
Hand out environmental information to boaters and answer related questions or refer
them to the Dockmaster.
Oversee management of wastes generated by hauling, launching, light boat
maintenance, bottom painting, and rigging.
Monitor yard crew use of environmental SOPs and BMPs.
Oversee management of wastes generated by engine maintenance work.
Oversee management of wastes generated by painting operations.
Oversee management of wastes generated by carpentry operations.
Understand what environmental SOPs and BMPs each must follow.
Report all spills, leaks or potential hazards to foreman.
Keep eye on customers and report suspicious acts to foreman.
Critical
Critical
Important
Critical
Important
Critical
Critical
Critical
Important
Critical
Critical
Critical
Critical
Critical
Critical
Critical
Important
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New England Marina Environmental Management Plan Workbook
Environmental Responsibility Assignments
Step 1: Position
In the first column of Worksheet 3—Assignment of Environmental Responsibilities, list the major
positions within the marina that have environmental responsibilities.
Step 2: Environmental Responsibilities
In the second column of Worksheet 3, identify all of the environmental management responsibilities
for each position.
Step 3: Designation of Importance Level
In the third column of Worksheet 3, designate each responsibility as either critical or important.
Step 4: Focus on Critical Responsibilities
Begin by adding critical environmental responsibilities to employee job descriptions.
Step 5: Review with Employee
Review the responsibilities with each employee to make sure that he/she understands what is
expected. Training will be given to each as needed.
Step 6: Focus on Important Responsibilities
Once all the critical environmental responsibilities have been assigned, begin adding important
responsibilities to employee job descriptions when needed. Consider phasing in these assignments
over the second year or more.
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New England Marina Environmental Management Plan Workbook
Worksheet 3—Assignment of Environmental Responsibilities
Position
Environmental Responsibilities
Designation*
* Designation = either Critical or Important
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New England Marina Environmental Management Plan Workbook
Section 4.
Having Standard Operating Procedures (SOPs)
Environmental Standard Operating Procedures are the specific steps an employee would take to
complete a job safely and in compliance with laws and regulations while contributing toward
efficient and productive operations. SOPs can be developed based on Best Management Practices
(BMPs), which are proven activities, practices or methods. SOPs can be designed to reduce pollution
by five basic methods:
• Preventing pollution from occurring (e.g., eliminating the source by changing products)
• Reducing the amount of pollution produced (e.g., using less toxic cleaners or using smaller
amounts)
• Capturing pollution before it can enter the environment (e.g., dustless sander)
• Trapping pollution before it can enter the environment (e.g., using ground filter cloth under
boats being worked on outside)
• Cleaning/removing pollution from the environment (e.g., oil spill absorption boom)
The BMPs selected for normal use in the marina become its SOPs.
An effective SOP includes a complete description of the procedure, including a step-by-step
breakdown of what needs to be done, and to whom the SOP applies. It should also include the date
the procedure was first issued and the latest revision date. This tracking is beneficial to help ensure
all necessary SOPs are completed.
Depending on the types of marina services offered, the number of SOPs will vary between marinas.
At first, it may not be feasible to develop and adopt all the SOPs you will need. Instead, you may
need to gradually add new SOPs over time to reach the marina's environmental goals.
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New England Marina Environmental Management Plan Workbook
Standard Operating Procedure (SOP)
Step 1: Get Organized
First determine what reference materials you will need to identify and define your SOPs. In
particular you may find your state marina guidance manual to be helpful for these activities. See also
Example 4a for some example SOP's of Salty Cove Marina.
List your marina SOP in the first column of Worksheet 4—List of Environmental SOPs. In the
second column, give the reason for developing the SOP (e.g., to support environmental
requirements).
Step 2: Assign Responsibility
Determine who needs to be involved with developing each SOP and list them in the third column of
Worksheet 4, "Who is Responsible." In column four, assign a target date to complete the
development of the procedure.
Step 3: Define and Describe SOP
For each SOP that needs to be developed:
a. Write a statement describing the SOP.
b. State who the SOP applies to.
c. Meet with key employees responsible for each SOP and develop a list of steps required to
complete the task. For this task, use your appropriate environmental references. If a particular
SOP seems very complex and takes many steps, consider whether more than one SOP is
needed to adequately cover all the aspects of the process selected.
d. Combine the information put together in steps a through c to develop a draft SOP.
e. Share the draft with key employees and ask for their comments and input before finalizing
each SOP.
Step 4: Communicate
Once finalized, the SOP should be communicated to relevant employees. Additional employee
training may be necessary to ensure conformance with SOP.
Step 5: Review
Periodically review the environmental references and environmental SOPs to ensure they reflect any
recent changes to environmental regulations or to processes within the business. Make sure that new
copies are distributed and that outdated SOPs are filed away.
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Example 4a: Some Examples of Salty Cove Marina's SOPs
Description of SOPs
Monthly waste counting and
identification
Why Needed
Comply with RCRA
Who Is Responsible
Environmental Coordinator
Fuel storage management
Comply with SPCC and
NPDES
Dockmaster, fuel dock crew
Boat sewage discharge pump
outs
To reduce bacterial
contamination of water to
protect shellfish
consumers and swimmers
All staff, especially dock staff
working on fuel and pumpout
dock
Dry dock maintenance
To remove contaminants
from ground before runoff
takes it into the bay
water; Comply with
NPDES
Boat maintenance staff
Oil spill control at fuel dock,
from bilges and engine
maintenance area
To prevent oil spills and
to prepare to control
minor spills; Comply with
SPCC and NPDES
Dock staff, boat service crew,
boat owners
Storage of hazardous waste
Comply with RCRA and
NPDES
Service Manager and boat
service crew
Collection and recycling or
disposal of used oil and
solvents
Comply with RCRA
Service Manager
Safety Coordinator
Environmental Coordinator
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New England Marina Environmental Management Plan Workbook
Worksheet 4—List of Environmental SOPs
Description of SOPs
Why Needed
Who Is Responsible
Target Date
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New England Marina Environmental Management Plan Workbook
Example 4b: Salty Cove Marina SOP
Note: The following SOP does not cover all environmental and safety requirements which might
apply including the following:
-Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)- for example, bottom paint repair may
require the use of a pesticide, which in certain instances call for a licensed applicator.
-National Emissions Standards for Hazardous Air Pollutant (NESHAP)- for example, depending on
the age of the boat and/or facility, and the work performed, federal and/or state asbestos requirements
may apply.
-Emergency Planning and Community Right To Know Act (EPCRA)- for example, facilities have
certain reporting requirements if there is a release into the environment of a hazardous substance that
is equal to or exceeds the minimum reportable quantity.
Salty Cove Marina
Bottom Paint Repair SOP
Date Created: 3/31/03 Date revised: 10/24/04
Prepared by: Salty Smith, Owner
Scope
This SOP pertains to repair of small areas of hard bottom paint only (less than ten square feet). Larger
jobs involving hard bottom paint must be conducted in the spray paint booth under the SOP for
bottom painting.
Personal Protective Equipment (PPE)
1. Refer to PPE Plan to select PPE for each task below.
2. Retrieve appropriate PPE from the PPE cabinet near the employee lockers in the main
repair building.
Remove Paint from Work Area
1. Sand boats only in the main repair building or the adjacent covered maintenance bay to
prevent sanding dust from blowing away.
2. Place nonabsorbent tarp, such as geotextile filter cloth, under the area of the boat to be
sanded. Tarps are stored in plastic bags on shelf above the sanding equipment.
3. Use vacuum sander only for mechanical sanding or wet sand for dust control.
4. Contain dust from manual sanding within tarped area if done outdoors.
5. When done sanding, vacuum dust from the tarp. Next, fold, bag and put away tarp.
6. Empty dust out of vacuum sander and place, with used sand paper, in the designated
storage area for appropriate disposal (a hazardous waste determination must be
conducted).
Prepare Surface for New Paint
1. Retrieve acetone container from flammable liquids storage cabinet. Carry it to the work
location in the drip pan hanging on the wall beside the cabinet, along with rags from the
bin labeled "Cleaning Rags." Do not use paper towels for surface preparation.
2. Keep acetone container in drip pan throughout the process to prevent and contain spills.
3. Position drip pan under the area to be cleaned.
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New England Marina Environmental Management Plan Workbook
4. For cleaning, pour acetone onto a rag, wipe surface and repeat until clean. Replace lid
tightly on acetone container.
5. Dispose of used rags in drum labeled "Solvent Contaminated Rags," replacing the lid
tightly.
6. If acetone spilled into drip pan, retrieve from the flammable liquids storage cabinet the
container labeled "Acetone for Reuse." Carry it to the work location in the second drip
pan, along with the funnel. Pour spilled acetone into the "Acetone for Reuse" container
using the funnel, while continuing to keep the second drip pan beneath it. Replace the lid
tightly when done.
7. Return acetone containers to the flammable liquids storage cabinet, carrying them in the
drip pan. Return drip pan, unused rags and funnel (if used) to storage locations.
Note: If any acetone spills outside of drip pan, follow emergency action plan.
Paint Surface
1. Place absorbent floor covering in an area big enough to capture all overspray. Absorbent
floor covering is stored on the shelf above the spray paint equipment.
2. Spray surface holding nozzle 12 inches from surface. Disengage trigger at the end of each
pass at edge of sprayed area. Spray at steady speed to keep excessive coating and
overspray to a minimum.
3. When finished painting, record quantity and product number of paint used in Paint Log,
located on top of the paint storage cabinet.
4. Clean spray gun using the SOP for Solvent Cleaning.
5. Place absorbent floor covering pieces that are dry and not heavily covered with paint in
bin labeled "Reusable Floor Covering," located on shelf above spray paint equipment.
6. Place paint-contaminated absorbent floor coverings, stir sticks or rags in the drum labeled
"Paint-contaminated Solids," taking care to replace the lid tightly.
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New England Marina Environmental Management Plan Workbook
Section 5.
Keeping Track of Information
Record Keeping
You must keep good records of the activities covered under your EMP. Indeed, some records must be
kept under state and/or federal laws. By keeping good track of essential records, you can easily
document that your marina is keeping its commitment to meet environmental regulations and
desirable environmental practices. Keeping good records is also often one of the biggest challenges
faced by marina owners/managers. When documents get lost, an otherwise good system can fall
apart.
Basic recommendations for record keeping are:
1. Keep all master files, SOPs and records in one place. The best way to keep the process simple
and safe is to designate a separate filing cabinet in your office just for environmental and
safety records. This will promote organization and easy access.
2. Know what is contained in environmental files and how to get to them quickly. This
knowledge can prevent many problems during any environmental emergency and will also be
very useful during inspections.
3. Assign someone to keep track of the files and records so that information gets changed or
updated periodically as required.
4. Use a document control list to keep track of all vital environmental records. Common master
files to consider include:
a. Environmental Management
b. Emergency Planning
c. Emergency Action
d. Training Records
e. Hazardous Waste Management
f. Wastewater Management
g. Stormwater Management
h. Coastal Construction
i. Air Management
See Examples 5a and 5b, for some examples of Salty Cove's master files and document list(s) and
suggested file organization.
Use Worksheet 5—Document List—to develop your files and document list.
Recommendations: 1) Require all subcontractors and outside contractors working in your yard to
also maintain environmental records related to their work in your marina. This helps build a reliable
paper trail should something go wrong.
2) For marinas who are required to maintain more than one federal plan, consider using EPA 's One
Plan. The "One Plan ", also known as Integrated Contingency Plan (ICP), allows a facility to
comply with multiple federal planning requirements by consolidating them into one functional
emergency response plan. The ICP places an emphasis on the use of pollution prevention as a
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New England Marina Environmental Management Plan Workbook
primary means of reducing or eliminating sources of risk. The ICP framework presents an excellent
platform for incorporating prevention into emergency response planning, by centralizing the
planning process and encouraging a broad, facility-wide approach, as opposed to a more limited,
process-specific focus. This tool would provide for time savings, for more continuous improvement,
and puts in place long term cost savings. The "Bolder " software program supports EPA 's One Plan.
(see" Some Useful Resources" on page 4)
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New England Marina Environmental Management Plan Workbook
Example 5a: Examples of Salty Cove Marina Master Files and Document List
(Note: Master File names are in bold, with reports and records listed below each.)
1. Environmental Management
• Environmental management plan
• Standard operating procedures (SOPs)
• Environmental contracts with
customers
• Environmental contracts with outside
contractors
2. Emergency Planning
• Emergency and hazardous Chemical
Inventory for TIER II
• Emergency Planning Notifications
• Material Safety Data Sheet List
• Emergency Release Notifications
3. Emergency Action
• Emergency call list
• Spill reporting call list
• Copies of emergency plans such as
hazardous waste contingency plan,
spill prevention, control, and
countermeasure (SPCC) plan,
stormwater spill preparedness plan
• Documentation and critique of
incidents that triggered emergency plan
• Reports of spills to regulatory agencies
4. Training Records
• Position description including
environmental responsibilities
• Rights to know agreement (signed)
• HazMat training
• Material safety data sheets (MSDS)
• Training certificates and the agendas or
topics list for each training session, in
chronological order, with the most
recent training first
5. Hazardous Waste Management
• Correspondence with regulators
• Hazardous waste communication plan
• EPA Generator ID number(s)
• Certificates of disposal (tipping and
solid waste)
• Chemical inventory of all products
used and sold (over past 10 to 15 years)
• Oil in and out records
• Contaminated fuel receipts
• Paint waste
• DOT sheets
• Waste determinations, chemical profile
reports, lab tests
• Current hazardous waste permits and
associated documents and
correspondence
• Employee training
• Contingency plan
• Hazardous waste shipment paperwork,
including all waste shipping manifests
• Inspection records
• Proof of insurance disposal companies
6. Wastewater Management
• Correspondence with local wastewater
treatment plant authority
• Copy of current sanitary sewer
ordinance
• Pre-treatment permit and associated
documents and correspondence
• Wastewater permit
• Sampling results
• Pumpout facility records
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New England Marina Environmental Management Plan Workbook
7. Stormwater Management
• Inventory of Stormwater drainage and
outfalls from your property (include
map)
• General Stormwater permit
• Stormwater pollution prevention plan
• Maintenance plan for Stormwater
infrastructure
• Stormwater permit (if applicable) and
associated documents and
correspondence
• Stormwater annual reports and
sampling results (if applicable)
8. Coastal Construction
• Permits for dredged or fill material
• Permits for structures
• Other Permits
• Applications
• Bottom sampling reports
9. Air Management (for work such as
boat fiberglass repairs or spray painting)
Correspondence with regulators
(inspection reports, regulatory
interpretations and other
correspondence)
Current permits for maj or or minor
sources and associated documents and
correspondence
Emission calculations for potential to
emit (PTE)
Annual air toxics' inventory
Inspection records and chemical usage
records as required by permit
conditions (e.g., VOC records, pressure
drop inspections, operating hours)
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New England Marina Environmental Management Plan Workbook
Example 5b: Some Examples From Salty Cove Marina's Document List
Document Master File Person Action Dates Review Distribution Location(s) of Document(s)
Responsible Frequency
Environmental
Management Plan
Emergency and
Hazardous Chemical
Inventory Form
HazMat training lists
Uniform Hazardous
Waste Manifest
NPDES Stormwater
General Permit
Pollution Prevention
Plan
SPCC plan
NPDES Stormwater
Permit
Water Quality Sample
Test Results
Emissions Calculation
Stage 1 Vapor
Recovery Maintenance
Test Results
Environmental
Management
Emergency
Planning
Training
Records
Hazardous
Waste
Management
Stormwater
Management
Emergency
Action
Stormwater
Management
Stormwater
Management
Air Management
Air Management
Marina Owner
or General
Manager
General
Manager
Marina Owner
General
Manager
General
Manager
Dockmaster
Marina Owner
Dockmaster
Boat Yard
Manager
Boat Yard
Manager
December
February
March
As required
April
February
As required
As required
As required
As required
Annual
Annual or as
needed
Biannual
Quarterly
Annual
Annual
As required
As required
As required
As required
All employees as
appropriate according to
job responsibility
All employees
SERC, LEPC and local
fire department
Customers, Store
Manager, Dockmaster,
Fuel Attendant
Maintained in file
Business Owner
and appropriate
employees as needed
Filed and posted for
view by all staff
Business Owners
All employees
Boat Service/Paint
Manager
Maintained in a file
Environmental file cabinet in main
office
Dockmaster office bookshelf
Repair shop desk
Main office file cabinet
Main office file cabinet
Main office file cabinet
Main office file cabinet
Main office file cabinet
Dockmaster office
Posted in plain view at oil storage
locations
Main office file cabinet
Main office like cabinet
Main office file cabinet, and posted
in main repair shop
Main office file cabinet
Definitions:
SERC - State Emergency Response Commission LEPC- Local Emergency Planning Committee VOC - Volatile Organic Compounds
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New England Marina Environmental Management Plan Workbook
Worksheet 5—Document List
Document Master Person Action Dates Review Distribution Location(s) of Document
File Responsible Frequency
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New England Marina Environmental Management Plan Workbook
Section 6.
Maintaining Communications
Communication by management to employees, customers and others about environmental matters
and successes is essential in every marina business. Good communication must be second nature to
all owners and general managers.
Implementing a solid communication plan for communication will help ensure that you, your
employees and managers stay involved with environmental management. In addition, a solid plan
will help ensure that they understand the business's environmental policy and are able to provide a
consistent message to the community about the business's commitment to environmental
performance. Good communication will also ensure that your staff and customers understand their
environmental responsibilities as required by regulations.
As your EMP comes together and the business develops a track record of environmental excellence,
you and your marina may benefit greatly by actively promoting the business's EMP with customers
and community officials as well as the beyond compliance expectations you set as part of your EMP.
Communication Planning
Step 1: Develop an INTERNAL Communications Plan
Identify ways to inform employees and customers, when they are in the marina, about your EMP and
its goals and list them in Worksheet 6a—Internal Communications Plan. Think about
communication opportunities via existing business meetings, demonstrations, guest lectures,
newsletters or customer events.
Decide with whom you need to communicate, what you need to communicate, how and when you
want to do it and who on the marina staff you will assign responsibility for overseeing each task.
Step 2: Develop an EXTERNAL Communications Plan
Using Worksheet 6b—External Communications Plan, identify all the potential people you need
to inform about your business's EMP. Consider who you will need to stay in touch with such as
neighboring business owners and marina industry leaders - including those at state and national
marine trade associations. Keep in mind the various marina assistance providers for government at
all levels including the state environmental management coastal zone representatives, city councilors
and harbor commissioners.
Decide the audience with whom you need to communicate, the message you need to communicate,
the timing, and the person on the marina staff you will assign responsibility for overseeing each task.
(Helpful hint: If you do not feel your business is ready to present its EMP "to the world," you can
leave out people listed in step 2 until next year, when you can consider this question again.)
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New England Marina Environmental Management Plan Workbook
Example 6a: Some Examples From Salty Cove Marina's Internal
Communications Plan
Creation date: January 2005
Date revised: October 2005
Audience Message Medium When Person
Responsible
All staff
and
managers
All staff
and
managers
Oil-
handling
employees
Boaters
and
customers
Update on BMP goals
Explain new SOP's
Annual discharge prevention
briefing required by SPCC
regulation
1 . Request suggestions for
improvement
2. Educate on waste disposal
practices
3. Explain boater related SOP's
used for pollution prevention
and adopt policy for lease
cancellation for noncompliance
with environmental policies
Presentation during
annual meeting
1 . Conduct training
through course and one
on one as needed
2. Review during staff
meetings and as part of
training
Conduct briefing session
1 . Post notices in dock
area, dumpster,
bathrooms and picnic
area
2. Post notice on bulletin
boards; invite customers
to information session
and annual picnic at
marina
3 . Update contract
language; announce in
quarterly newsletters
February
February
March
February
April
September
November
Owner
General
Manager
Manager
Dockmaster
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New England Marina Environmental Management Plan Workbook
Worksheet 6a—Internal Communications Plan
Creation date: / /
Audience
Message
Medium
Person Responsible
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New England Marina Environmental Management Plan Workbook
Example 6b: Some Examples From Salty Cove Marina External Communications
Plan
Creation date: January 2005
Date revised: October 2005
Audience Message Medium When Person Responsible
Town
Mayor/Administrator
Harbor Commission
US Coast Guard
SERC, LEPC and
local Fire Dept.
Fire Chief
Community and press
High school class
Demonstrate that our
business wants to be a
good neighbor
Be a good neighbor
Show spill prevention and
containment preparation
Annual Tier II Emergency
and Hazardous Chemical
Inventory Form completed
Plan fire safety/response
plan; chemicals present
Describe environmental
efforts and commitment
Demonstrate
environmental BMP's to
local science class
Present talking points at
quarterly breakfast
meeting
Review plans during
annual meeting
Review spill plan and
equipment
Submit through mail
Conduct annual fire
safety review
Distribute press release,
and conduct open house
with photo opportunities
Host student field trips
March
February
Within 60
days
Early
February
February
April
October
Owner
General Manager
General Manager
General Manager
General Manager
Owner and
General Manager
General Manager
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Worksheet 6b—External Communications Plan
Creation date: / /
Message
Medium
Person Responsible
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New England Marina Environmental Management Plan Workbook
Section 7.
Conducting Training
Training employees about environmental management responsibilities is essential, and it is required
by most environmental regulations. Trained employees will understand how their responsibilities
contribute toward meeting the goals of your EMP.
Here are some suggestions for establishing an effective training program:
1. Make sure training programs are provided as required by regulations.
2. Set up a plan for the year. Set priorities while establishing a training plan so that the critical
training takes place first.
3. Include what type of training needs to happen, who the teacher will be, where it will be done
and a target date to do it.
4. Train employees on good practices that will improve efficiency, save time or money, and help
the business be proactive.
5. Train all staff who handle chemicals about spill or release response.
6. Record all training for each staff member; include training date, subject covered and
instructor.
7. Follow-up on observations of staff usage of the EMP and SOPs and provide immediate
corrective instruction as needed.
8. Review training requirements and revise the plan on an annual basis.
The marina owner, general manager, dockmaster and other key managers should receive outside
professional environmental training if possible. This includes activities such as attending state,
regional and national marina environmental workshops or conferences sponsored by marine trade
associations and government agencies. As a general practice, the owner and general manager should
try to attend such training programs every year to help keep current on environmental regulations,
best management practices and available new technology for marina and boat use.
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New England Marina Environmental Management Plan Workbook
Training Planning
Step 1: Required Training
To develop a comprehensive list of training regulations, use the marina environmental references
referred to on pages 4-5 and check with local, state, and federal regulations to identify training that is
required by applicable laws. List them on Worksheet 7 a—Required Training. List the regulation
name or code citation.
Step 2: Training Overview
Use Worksheet 7b—Training Overview to set up training for the staff. This step will indicate
whether a class needs to be devoted to the training topic, or whether one-on-one, on-the-job training
(OJT) is needed. New hires need immediate one-on-one training on appropriate SOPs. Use the
worksheets to help with this analysis.
Step 3: Annual Training Plan
Fill out Worksheet 7c—Annual Training Plan, using the information developed in steps 1 and 2 to
develop an Annual Training Plan. Winter is often a good, slow time to do most training, but some
training will have to occur in season. See Example 7 (on page 39) for some examples from Salty
Cove Marina's Training Plan.
Step 4: Training Plan for Each Employee
Develop a training plan for each employee using Worksheet 7d—Individual Employee Training
Plan. This plan should include general and specific training requirements as needed. Use the
worksheet to keep track of each employee's training progress.
Step 5: Review Training Plan
Annually review the marina's overall training plan to help ensure employees have had adequate
training, to identify opportunities for improvement and to make changes as needed based on training
experience and new regulations and technology. Ask the employees for suggestions on ways to
improve training and ideas for new training courses.
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New England Marina Environmental Management Plan Workbook
Worksheet 7a—Required Training
Regulation/Code Citation
Training Required
1.
Worksheet 7b—Training Overview
# of Employees to Train
How Often?
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New England Marina Environmental Management Plan Workbook
Example 7: Some Examples From Salty Cove Marina Training Plan
What Training Training Type1 Trainer When Scheduled Completed
Candidate
1 . Emergency
procedures-new
SOP's
2. Hazardous
waste-new SOPs
3. Stormwater
pollution
prevention-new
SOP's
4. Wastewater-
new SOP's
5.
Environmental
new regulations
and BMPs
All employees
All employees
All employees
For
maintenance
technicians
Marina Owner,
GM
Class
OJT for new
staff
Class
Briefings
lonl
Class
OJT for new
staff
lonl
Annual marina
trade
conference
Dockmaster
General manager
Dockmaster
Maintenance
manager
Environmental
coordinator
Maintenance
manager
Professional
marina
environmental
experts
Annual (March)
As hired
Annual (October)
Monday staff
meetings and
as needed
Annual (July)
As hired
Annual (January)
Annual (February)
3/15/05
Variable
7/15/05
5/15/05
3/31/05
:Key for type of training:
OJT = on-the-job training for new hires
Briefings = short updates during weekly staff meetings
Class = classroom
1 on 1 = one-on-one meeting with talking points on a handout
Worksheet 7c—Annual Training Plan
What Training Training Trainer When scheduled Completed
Candidate Type
1.
2.
o
J.
4.
5.
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New England Marina Environmental Management Plan Workbook
Worksheet 7d—Individual Employee Training Plan
Training Plan
Employee Name:
Employment Date: / /
Termination Date: / /
Job Title:
Type of Training
Training Requirements
1.
2.
3.
4.
5.
6.
7.
Training Dates
2005
2006
2007
2008
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Section 8.
Maintaining the EMP—Monitoring and
Taking Corrective Action
Monitoring and taking corrective actions are important components of the EMP because they help
verify if you are on the right track and provide a method to get back on track if operations have
strayed. The marina's environmental manager oversees the monitoring, works with the staff and
reports to the owner about changes needed.
Environmental monitoring must be an ongoing part of your daily marina routine and needs to be
scheduled at required set intervals. When a critical problem is observed, management must take
immediate corrective action. As one marina manager said, "Monitoring is a no-brainer. It is an
everyday occurrence for us. The key is understanding environmental regulations and for everyone to
know what to do."
Environmental Compliance Monitoring
This type of monitoring determines whether the business is in compliance with regulations, including
whether employees are following Standard Operating Procedures (SOPs) and Best Management
Practices (BMPs) that contribute to compliance. Most marina environmental monitoring will be
informal, such as day-to-day observations by marina personal, but will also include more formal
weekly/monthly reviews and annual inspections done by marina management. Any noncompliance
found should be immediately corrected.
Audits are a good way to determine compliance with regulations and to observe whether your
employees are following SOPs and BMPs. You can conduct audits internally or hire an outside
expert. You can also enlist managers to do performance checks in the course of their daily work.
It is a good idea to conduct a comprehensive compliance audit every few years to ensure that you
have not overlooked any new activities within your marina that may affect the environment or any
new or changed regulatory requirements. Your state marina guide may contain useful information to
help you complete an audit of your marina facility. Also, your state environmental agency or marine
trade association may be able to assist with compliance auditing. Keep in mind, by conducting a
compliance audit of your facility you will likely be verifying your knowledge of regulations which
apply to your facility including areas of non-compliance. You will need to be committed to correcting
any problems you identify in your compliance audit (see Appendix A for an environmental checklist
to use as a tool to spot check for compliance). You should also consider using incentive policies (see
page 9) which are designed to encourage greater compliance with environmental regulations and
laws.
Environmental Performance Monitoring
Environmental performance monitoring allows you to verify whether your marina is meeting the
goals stated in your EMP. It does this by measuring the progress you've achieved towards those
goals. These measures are usually expressed in numbers, such as the reduction in pounds of waste
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New England Marina Environmental Management Plan Workbook
generated or pounds of volatile organic compounds (VOCs) emitted. For example, if your goal is to
reduce hazardous waste, then your measure of success could be the number of pounds of waste
reduced over a year's time.
An environmental target indicates by how much you want to achieve a goal. For example, your
target might be to reduce hazardous waste amounts by 10 percent within one year. Articulating
specific targets and desired end results will help you achieve your marina's environmental goal. As
your marina BMP matures, goals and targets need to be revisited. You may choose to keep the same
goals, but change the targets to reflect a higher performance expectation. Or, you may choose to retire
certain goals and adopt new ones to reflect new environmental management challenges your business
is facing. The idea is that the goals and targets should work together to fuel ongoing improvement to
the BMP.
Refer back to Section 2 (on page 11), Selecting Goals and Setting Targets, and use this guide to
identify meaningful targets for stated goals.
Management Review
The marina top management team should conduct the BMP review internally. This will help ensure
that it is functioning as planned. Seek the opinions and suggestions of managers and staff prior to
meeting and before making decisions. This is an excellent opportunity to make changes to the BMP
and report on environmental performance.
Management reviews should be done at least once annually and include:
• Reviewing the BMP to see if it effectively meets your marina business and environmental
needs. This review should include confirming compliance with all local, state and federal
laws.
• Developing recommended options to improve the BMP as a key to continual improvement.
• Determining what environmental goals and targets are still applicable or need to be updated.
• Revising or establishing new targets to assure the BMP is being met.
Also consider the BMP system of action and accountability throughout the marina, and look at the
results of monitoring to see how well the BMP is working to achieve compliance and to meet its
stated goals. Other questions you might consider include:
• How much value is the BMP returning to the business for the effort invested?
• Are environmental management costs higher or lower than this time last year?
• Are employees knowledgeable about their environmental responsibilities?
• Is it taking less time overall for your business to meet regulatory requirements?
• Have your boating customers joined the effort by using clean boating practices?
Use Worksheet 8a—Management Review to work through the management review process.
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New England Marina Environmental Management Plan Workbook
Corrective Action
Take corrective action if compliance monitoring identifies nonconformance with any applicable laws
or with the EMP. In general, do the following for corrective action:
1. Investigate the root cause of the problem.
2. Create a solution to correct the existing problem as well as to prevent recurrence of the problem.
3. Assign responsibility for corrective and preventive action.
4. Ensure that the problem has been solved.
Use Worksheet 8b—Corrective Action to help work through the process.
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New England Marina Environmental Management Plan Workbook
Worksheet 8a—Management Review
Top Management Reviews the EMP and Monitoring Results
Review your EMP and the results of audits and performance monitoring conducted over the past
year.
Step 1: Evaluate the EMP's Usefulness
Consider these questions when evaluating your EMP:
a. Is compliance with environmental regulations being achieved? If not, why not?
b. Is the environmental policy still appropriate for the marina's activities and culture?
c. Are goals and targets being met? If not, why not?
d. Are the goals and targets still adequate for keeping the business on track with environmental
policy?
e. Has the EMP added value to the business by:
Making environmental compliance more effective? Yes No
Making environmental management less time consuming? Yes No
Causing changes to processes or procedures that reduced liability? Yes No
Causing changes to processes or procedures that saved money? Yes No
f. How does the EMP detract from the business? What can be done to prevent or reduce this from
happening?
Step 2: Determine How the EMP Can Be Improved
Based on responses to the questions in step 2, what are the three most critical issues that need to be
addressed to improve your EMP? If the critical issues have been taken care of, what are the three
most important issues?
a.
c.
Step 3: Discuss the Corrective Action Plan
Meet with the responsible staff to talk about the issues identified in step 3. Discuss what changes
need to be made to address or improve them and assign responsibility to ensure implementation.
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New England Marina Environmental Management Plan Workbook
Worksheet 8b—Corrective Action
Step 1: Identify and Describe the Problem
Briefly describe the identified problem.
Step 2: Investigate the Problem
Investigate the problem by asking members of the clean marina team and any involved employees
what they believe is the root cause of the problem. Also, collect other useful observations such as
those from customers and venders.
Step 3: Determine Possible Corrective Steps
Determine possible corrective and preventive actions that the business can undertake to respond to
the problem. Involve members of the clean marina team in a brainstorming session to develop a list
of corrective and preventive steps.
Step 4: Select the Steps to Take
From the list of corrective and preventive actions developed, decide which one or two will be most
effective and feasible given available resources. Write a memo briefly stating the problem, what
corrective and preventive actions the business will take, and who will be responsible to oversee
implementation.
Step 5: Inform Those That Need to Know
Distribute the memo to all appropriate parties. Check in with those who have follow-up
responsibilities to make sure they understand what needs to be done.
Step 6: Calculate How Much Time is Needed
Decide how much time should pass before checking to see if the corrective and preventive actions are
working. Put a reminder in your calendar.
Step 7: Evaluate Results
When the time comes, evaluate the results of the corrective and preventive actions and consider
whether the EMP needs to be revised to reflect a better approach to this particular issue for the future.
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Section 9.
Creating a Master Calendar
Creating a master calendar can help you ensure that all important activities, such as planning training,
compliance with regulatory requirements and deadlines, are done when required or needed and when
best fit into the marina's work schedule. Using a calendar will also save you time in the long run and
will remind staff what to do and when.
Step 1: Review Master File List
Review Worksheet 5—Master File and Document List to identify all the reports, notifications and
permits the business must file with regulatory agencies. Make an index card for each report and note
to what agency (or agencies) it must be submitted, the person responsible for compiling and
submitting it, any supporting internal reports or data necessary to produce it, and the person(s)
responsible for providing that information. Put the due date for each report in one of the upper
corners of the index card.
Step 2: Rank in Calendar Order
Review Example 9 (on page 47) for some examples of Salty Cove Marina's Environmental Master
Calendar, to see how a typical schedule is organized.
List what your marina needs to do, in order, by due date, on Worksheet 9—Environmental Master
Calendar. The calendar will serve as a helpful guide for everyone involved with key environmental
activities you wish to schedule for the coming year. Display the master calendar on bulletin boards as
a reminder of what must be done each month.
Step 3: Do an Annual Review
Check the requirements of regulations annually (or more often) to check if any reporting or
notification requirements have changed. Revise the Environmental Master Calendar as needed.
Step 4: Keep Tabs on New Report Needs
Check with the clean marina team to see if new internal reports are needed to fulfill revised goals, or
if any current internal reports are no longer needed. Revise the Environmental Master Calendar
accordingly.
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New England Marina Environmental Management Plan Workbook
Example 9:Examples From Salty Cove Marina's Environmental Master Calendar
Month Who Does It What Is Done Where Done Special Instructions
January
February
March
April
May
June
July
August
September
October
November
December
Marina Owner
and General
Manager
General Manager
Marina and Yard
Managers
General Manager
Yard Manager
Service Manager
Yard Manager
Dockmaster
All Staff
Yard Manager
All Managers
Service Manager
Paint Crew
Manager
Marina Owner
and General
Manager
Attend national marina conference
Organize EMP training programs
Update stormwater pollution
prevention plan
Submit annual Tier II Emergency
and Hazardous Chemical Inventory
Form
Train staff on SOPs from EMP
SPCC plan review
Collect and recycle shrinkwrap
Collect and recycle antifreeze
Train staff on hazardous waste
Install dump station for portable
toilets
Conduct boater educational
program
Observe boater compliance with
BMPs for boat use
Promote pumpout use
Take stormwater runoff samples
for testing
Inspect marina and yard for
environmental improvements
Educate staff on use of MSDs
Track and record spray painting
VOC volumes
Review EMP and SOPs
Prepare new year's environmental
master calendar
Conference
site
Marina
Repair shed
Yard
Service
building
Dock
Dock
Dock
Point sources
Marina-wide
Service office
and building
Service office
Main office
Collect newest
information to update
EMP
Review changes with
appropriate staff
Send to SERC, LEPC
and Local fire
department
All participants sign
in
Sent to recycler
Sent to recycler
Update training
records
Place in convenient
location near steps
Demonstrate good
pollution prevention
Encourage use of spill
pads at fuel dock
Sample during heavy
rain storm
Report findings and
recommendations to
general manager
Update training
records
Annual air emissions
inventory information
Discuss with all key
managers and staff for
their input and ideas
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Month
New England Marina Environmental Management Plan Workbook
Worksheet 9—Marina Environmental Master Calendar
Who Does It What Is Done
Where Done Special Instructions
January
February
March
April
May
June
July
August
September
October
November
December
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New England Marina Environmental Management Plan Workbook
Section 10.
Summary and Next Steps
As you can see, you and your staff can develop a marina EMP by following a series of manageable
steps. Each step results in steady progress towards integrating environmental management into
responsible boating facility practices. The EMP process is also designed with steps to review, and
with opportunities to improve performance. This adds considerable value to your marina and can
positively impact the environment.
Take time to develop your EMP and keep in mind that planning is important so that the effort does
not detract from other marina activities. Define the boundaries of implementing an EMP at the
beginning of the process and stay within them. During this initial time, to ensure efficiency and
success, some fundamental decisions should be made such as:
• Should the EMP cover the entire business to start out or will it focus on key processes?
• Must the initial focus be on assuring compliance with applicable laws, or can it be on
environmental performance that goes beyond compliance?
• At what stage should the EMP be shared with people outside the business?
Once your EMP is fully established, your marina will have systems and controls in place to help your
facility achieve high-level environmental performance on a sustained basis. This includes having a
framework to ensure it is in compliance. Beyond compliance, your marina will benefit in many ways
including increased employee satisfaction as your employees better understand what's expected of
them; increased savings as you more easily identify opportunities to reduce use of natural resources;
and increased available labor as the time your employees have to devote to environmental
management activities is kept at reasonable level.
Moreover, once your marina EMP is established, consider using it as the foundation for getting
public recognition—such as outside recognition by your state Clean Marina Program. Potential
customers who view your marina as clean will be more willing to patronage your marina.
The marina owner may apply for state "clean marina" recognition.4
Help is Available
Finally, remember that help is available! Your state Small Business Assistance Program, as well as
the EPA New England Regional Office of Assistance and Pollution Prevention (617-918-1836), can
answer your questions about regulatory requirements or broader issues of environmental
management. If you're uncertain about how to get in touch with the state Small Business Assistance
Program, consult www.smallbiz-enviroweb.org.
Contact your state coastal or environmental agency about clean marina programs that currently exist
in Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont.
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7/19/04
MARINA CHECKLIST
For All Questions, Please Use:
Y: Yes N: No DK: Don't Know NA: Not Applicable
Facility Type
1. a. How many employees work at the facility during peak recreational boating season? Full-time
Part-time
b. How many boats(capacity) are moored at the facility? Docked? Stored on land? _
2. a. Are maintenance or repair operations performed at the facility?
b. If yes, are these primarily customer do-it-yourself activities?
Hazardous Waste
3. a. Are manifests documenting hazardous waste shipments kept, going back at least 3 years?
b. Do employees receive training in: Proper handling of wastes? Emergency procedures?
c. Are quantities of hazardous waste generated by the marina calculated each month, to determine
what size generator the marina is?
d. Are all hazardous wastes stored: In labeled containers? In a dedicated storage area?
Indoors or covered? In an area with an impervious floor?
With storage area spill containment?
e. Are all hazardous wastes shipped with a properly licensed transporter?
Oil and Fuel
4. a. Is oil (including motor fuel) stored above ground in any size tank(s) with a total aggregate volume
over 1320 gallons?
Below ground in any size tank(s) with a total aggregate volume over 42000 gallons?
b. Is a Spill Prevention, Control and Countermeasure plan (SPCC):
On site? Signed by a registered professional engineer? Posted in plain view at oil
storage locations?
5. a. Does above ground oil storage (including piping system) have: Secondary containment? Leak
detection?
b. Does below ground oil storage (including piping system) have: Secondary containment? Leak
detection?
c. Are spill prevention procedures in place for:
Receiving oil from a supplier? Transferring oil within the facility?
Waste oil disposal?
6. a. Does the facility have spill prevention procedures in place for fuel dispensing?
Overfill alarm? Automatic shutoff? Fuel collars to capture splash/drips?
Employee monitoring of fueling? Other?
b. Is equipment available and procedures in place to contain a spill at the dispenser location?
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c. How would you evaluate the effectiveness of the methods you are using to prevent releases?
Excellent Good Fair Poor
Hazardous Materials
7. Has the amount of each hazardous material stored onsite been calculated (including motor fuel in
above-ground systems of greater than 10,000 pounds capacity) to determine if reporting to the
Local Emergency Planning Committee is necessary?
8. Are up to date Material Safety Data Sheets (MSDS) for all hazardous chemicals kept on file?
Used for training all employees handling hazardous chemicals?
Storm Water
9. a. Is a National Pollutant Discharge Elimination System (NPDES) Storm Water Permit required of
this facility?
b. Does the marina have a NPDES Storm Water Permit?
10. a. When pressure washing boats coated with ablative paints, are any efforts undertaken to prevent
removed material from releasing to water? from contaminating land?
b. Are blasting, other paint preparation and painting activities contained or controlled to prevent
abrasives, paint chips, and over spray from being released to the water? to land? to
protect employees?
c. Are all engine fluids promptly transferred from parts, drip pans, used filters and other containers to
closed receptacles for disposal or recycling?
d. Are fuels, solvents and paints stored in a protected, secure location, away from drains?
Plainly labeled?
11. Has the marina made structural changes to minimize surface water runoff? Berming?
Vegetation? Riprap? Drains? Placement of filters in drains?
Other?
Other
12. Has the facility switched to alternative materials or products to reduce toxicity or other hazards to
Health, safety or the environment? Safer paint stripping? Safer painting?
Safer MSD odor chemicals? Dust collection? Phosphate free cleaners?
Biodegradable cleaners? Safer antifreeze? Other?
13. Does the facility have a sewage pump out system? Onshore Boat How many
gallons (approx) do you pump out per week? Do you use Clean Vessels Act funds?_
14. Has the marina taken any action to improve environmental performance not included above? Please
explain
This checklist does not include all marina requirements and prefer able practices. For further
information, see EPA New England's regional marina website at: (http//www.epa.gov/regionl/marinas) .
In addition, your comments or suggestions can be sent to: U.S. EPA New England, Mail Code SPP-
Marinas, One Congress St., Boston, MA, 02114
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