Title : Fuel Tanks & Berms-McMurdo Type : Antarctic EAM NSF Org: OD / OPP Date : December 31, 1992 File : opp93097 DIVISION OF POLAR PROGRAMS OFFICE OF THE ENVIRONMENT 202/357-7766 MEMORANDUM Date: December 31, 1992 From: Environmental Officer, DPP Subject: Environmental Action Memorandum (Installation of Waste Fuel Holding Tanks and Berms, McMurdo Station) To: Safety and Health Officer, DPP Facilities Engineering Projects Manager, DPP Environmental Engineer, DPP Environmentalist, ASA Commander, NSFA REFs: Environmental Action Memorandum (Collection of Earth Fill Materials at McMurdo Station During the 1992-1993 Season), Dated December 1, 1992 Environmental Action Memorandum (McMurdo Station Sewer Outfall Quay Reinforcement Project), Dated December 30, 1992. This Environmental Action Memorandum describes the need for, and location of, proposed actions to install holding tanks for waste fuel collected at McMurdo Station and awaiting retrograde from Antarctica on the annual fuel supply vessel. The Environmental Officer posed a set of questions relating to the proposed actions, and to the potentially affected environment. These questions were responded to by Antarctic Support Associates, Inc.'s (ASA) Environmental Engineer, C. Andrews; and Mechanical Engineer, S. Bredl on December 31, 1992; background information as well as the questions and responses are shown below: Background As part of maintaining McMurdo Station's fuel storage and transfer system, and general station operations, waste fuel is generated. McMurdo's waste fuel, colloquially termed "slop", consists of fuels contaminated with such substances as water, dirt, oil, or antifreeze. Most waste fuel comes from one of two sources: 1) fuel pumped from the bottom of fuel storage tanks that have been found to contain too much sediment; and 2) fuel recovered from spills. In the past waste fuels have been stored in two tanks located on Hut Point. The fuel is transferred annually from the waste fuel tanks to the oil tanker for retro- grade from Antarctica and refinement, and reuse elsewhere. The existing waste fuel tanks near the pier leak and are not in useable condition. Two 57,000 liter (15,000-gallon) tanks previously located at New Zealand's Scott Base have been placed temporarily as shown on Attachment 1. These tanks would be used as the proposed new waste fuel tanks. The Contractor proposes to construct a secondary-containment area lined with 100-mil, high- density polyethylene (HDPE). The replacement tanks would then be installed within the containment area. GENERAL 1. What is the specific purpose of the proposed activity? The purpose of the activity is to replace McMurdo Station's existing waste fuel holding tanks. What alternatives to the proposed activity have the Program and the Contractor considered? The Contractor has considered four main alternatives: 1. using different tanks; 2. identifying different locations for the new tanks; 3. repairing the existing tanks; and 4. the "no-action" alternative. Have probable impacts of all alternatives been considered by the Program and the Contractor? Please explain how. The potential impacts of the proposed activity include changing surface water flow patterns; generation of fugitive dust emissions during installation; and, improvement to the integrity of the waste fuel storage system at McMurdo Station. Purchasing and installing different tanks (e.g., double-walled tanks) would cause significant delay in replacing the existing tanks that, currently, have no secondary containment; and, this would increase the costs of the project, overall. The proposed location was selected so as to minimize the aesthetic and potential environmental impacts (e.g., possibility for accidental spills during transfer of waste fuels into and out of the waste fuel holding tanks). This would be accomplished while meeting the operational requirements of the station's fuel system. For repair, if they are repairable, the existing tanks would have to be emptied with other holding tanks being used during the repair. This would be similar to the proposed and preferred activity. Should the chosen alternative involve potential impacts, how would these impacts be mitigated by the Program or the Contractor? The flow of water around emplaced secondary-containment berms for the new waste fuel holding tanks would be designed to avoid promotion of water ponding. Any ditches around the containment berms that would prove steep enough to cause excessive erosion would be lined with "rip rap" or with a metal, open-channel culvert. Dust emissions would be minimized by spraying water during installation, when feasible. Aesthetic impacts would be considered when selecting the exact location of the containment berms relative to the adjoining hillside and road. Have measures to assess the indirect costs of the proposed activity been identified or considered by the Program or the Contractor? Please explain how. Yes. The replacement tanks are previously used tanks with substantial remaining, useful life. This avoids the costs of purchasing and shipping new replacement tanks long distances to McMurdo Station. The former waste fuel tanks can not be reused unless they are rehabilitated so as to meet such Fuel Tank Container Codes as NFPA 30 and API 650. The lined, bermed area would require more maintenance (i.e, snow removal, and liner inspection) than the existing, unlined, tanks. The secondary containment would greatly reduce, however, the chances for contamination of the surrounding area and associated clean-up costs. LAND USE AND PLANNING 2. Where would the proposed activity be located, specifically? The replacement tanks would be placed at the base of the hill beneath Bulk Fuel Tank "D-1" on the northeast side of the main road to Hut Point. See attached map. Have alternative locations been considered by the Program or the Contractor? If yes, which are they; if no, explain why. Yes. The Contractor considered placing the new waste fuel holding tanks in the area between Bulk Fuel Tanks "D-1" and "D-2". This location was rejected according to an American Petroleum Institute code. Under that code and at that site the minimum distance required between tanks would not be achievable. Placing the replacement tanks near the site of the existing waste fuel tanks near the station's ice wharf was rejected as: 1) the new site would reduce driving distance to tanks; 2) the new site is farther from the water, reducing the potential for a waterborne spill; and, 3) tanks at the proposed site may still be emptied directly into the oil tanker using flexible hose (i.e., the "dry-break" type of hose used to transfer fuel to Williams Field) or using the station's tanker truck. Also, creating a site for the replacement waste fuel tanks on the other side of the road, nearer Building 183, was considered. This location was rejected due to the quantity of local earth fill required to create a level area, and due to safety concerns associated with the steep embankment along the other side of the road. 3. How would any aesthetic impacts to the area from the proposed activity be handled by the Program or the Contractor? The new tanks would be placed within a lined, bermed containment area. The Contractor would emplace the berms to fit the natural aspect of the area as well as its current topography. Removal of the existing, rusted waste fuel tanks (that are surrounded by fuel-soiled earth and with debris associated with their supports) would improve the aesthetics of the area along the road to Scott's Hut. This road is often used for recreational walking. Also, the existing waste fuel tank site is highly visible from ships. 4. Would the proposed activity have any other indirect impacts on the environment? If yes, what are they; if no, explain why none are expected. Yes. Approximately 50 cubic meters of local earth fill material would be required to construct both a level area and the containment berms. Actions associated with collec- tion of earth fill during the 1992-1993 season have been considered in a previous Environmental Action Memorandum. 5. Would the proposed activity change the traditional use(s) of the proposed (or chosen) site? If yes, how; if no, why. Currently, the site is a small, vacant area between a road, a steep hillside, and fuel lines on stanchions. The area is near existing fuel storage and transfer structures. The area clearly has been regraded one or more times in the past as part of installing the pad for Bulk Fuel Tank "D-1" and creating the roadway. 6. Are the physical and environmental characteristics of the neighboring environment suitable for the proposed activity? If yes, explain why; if no, explain why. Yes. The proposed site is relatively near to the points of generation of waste fuel, yet, it is not in a highly populated area. The existing hillside, utility pole and fuel lines would be worked around as necessary to fit the tanks and berms into the proposed space. The site is environmentally suitable and preferable over a site that has not been disturbed previously. IMPACT AND POLLUTION POTENTIAL AND ENVIRONMENTAL MANAGEMENT: 7. How has protection of the environment and human health from unnecessary pollution or impact been considered for the proposed activity (includes such considerations as pollution abatement or mitigation, and waste management [e.g., of noise, dust, fuel loss, disposition of one-time-use materials, construction wastes])? Placing the tanks near a road may entail safety concerns. The containment berm, however, would help to protect the tanks from a vehicle or falling cargo accident. The pro- posed activity would reduce the amount of fuel loss to the environment by allowing the existing, leaky waste fuel tanks to be retired and they would provide secondary containment for the replacement tanks. 8. Would the proposed activity change ambient air quality at the proposed (or chosen) site? If yes, how; if no, why. No. Dust emissions during berm construction would be suppressed using sprayed water, when feasible. The structures resulting from the proposed activity, two tanks sitting within a bermed area, would be passive and would not produce air emissions. During transfer of waste fuel into and out of the tanks some volatile petroleum compounds would escape. However, this would not differ from the type or quantity of emissions resulting from use of the current waste fuel tanks. 9. Would the proposed activity change water quality or flow (drainage), at the proposed (or chosen) site? If yes, how; if no, why. Yes. Ditches would be constructed to divert surface water around the secondary containment berms. The ditches would direct water back into the existing drainage system. 10. Would the proposed activity change waste generation or management at the proposed (or chosen) site? If yes, how; if no, why. No. The tanks would hold waste fuel and not affect the quantity of waste fuel generated. As all tanks involved in the project would be cleaned and reused (in actions to reinforce McMurdo's wastewater outfall quay) the old tanks would not become waste. Efforts made by the Contractor and the Naval Support Force Antarctica to reduce fuel spills would help reduce the amount of waste fuel generated. 11. Would the proposed activity change energy production or demand, personnel and life support, or transportation requirements at the site? If yes, how; if no, why. No. The tanks and berms would not require energy once they are in place. Energy and vehicles would be required to construct the berms and place the tanks. 12. Is the proposed activity expected to adversely affect scientific studies or locations of research interest (near and distant, in the short-term and in the long-term)? If yes, how; if no, why. No. The proposed activity would not occur near any sites of scientific research, nor would it produce adverse air or water emissions, electromagnetic interference, or noise. 13. Would the proposed activity generate pollutants that might affect terrestrial, marine or freshwater ecosystems within the environs of the station or inland camp? If yes, how; if no, why. No. No such ecosystems exist in the vicinity of the proposed activity. 14. Does the site of the proposed activity serve as habitat for any significant assemblages of Antarctic wildlife (for example, mosses or lichens, or antarctic birds or marine mammals)? No. The site is near a small area where surface water tends to pond. The color of the ponded water has turned green, indicating the presence of algae. However, the proposed construction would not affect the pond. The ponded water appears on occasion to be contaminated with petroleum products as a result of past fuel spills, indicating it has already been affected by human activity. HUMAN VALUES 15. Would the proposed activity encroach upon any historical property of the site? If yes, how; if no, why. No. The vacant area is not considered historical property. OTHER CONSIDERATIONS 16. What other environmental considerations may be potentially affected by the proposed activity at the proposed (or chosen) site? For example, have impacts associated with decommissioning of the activity been considered (and how). The tanks could be removed easily from the site in the future. The liner could be removed from the berms and the fill material could be regraded as necessary as part of decommissioning. Finding The Environmental Officer, after reviewing the information provided above, believes that the proposed activity will pose less than minor and less than transitory effects to the environment near McMurdo Station. The proposed activity is expected to have beneficial impacts with respect to enhancement of fuels and waste management at the station. With adherence to U.S. Antarctic Program policy on earth fill materials collection the proposed activity will improve the environment within and near McMurdo Station. The Program and the Contractor are authorized to undertake the proposed actions. Sidney Draggan Attachments