Title : Fuel Removal-Weddell Type : Antarctic EAM NSF Org: OD / OPP Date : May 20, 1992 File : opp93063 DIVISION OF POLAR PROGRAMS OFFICE OF THE ENVIRONMENT 202/357-7766 MEMORANDUM Date: May 20, 1992 From: Environmental Officer, DPP Subject: Environmental Action Memorandum (Fuel Removal from the Ice Station Weddell) To: Files (S.7 - Environment) Ocean Projects Manager, DPP Field Projects Manager, DPP REFS: Environmental Action Memorandum (Assessment of Soviet Proposals for Systems for Management of Liquid and Gaseous Wastes from the Drifting Station in the Weddell Sea); Dated January 11, 1991. National Science Foundation. 1991. Safety, Envi- ronment and Health Officer, DPP, Memorandum: Weddell Sea Ice Camp. May 17, 1991. National Science Foundation. 1991. Ocean Projects Manager, DPP, Memorandum: Environmental Issues for the Drifting Ice Station. May 29, 1991. National Science Foundation. 1991. U.S. and Soviet Researchers Will Drift Together for Months in Antarctica to Learn of Ice's Role in Climate Change. NSF Press Release No. 91-65 (July 10, 1991). Environmental Action Memorandum (Weddell Sea Ice Camp); Dated October 10, 1991. Environmental Action Memorandum (Emergency Airdrop of Fuel at Weddell Sea Ice Camp); Dated March 31, 1992. Environmental Action Memorandum (Follow Up on Emergency Airdrop of Fuel to Weddell Sea Ice Camp); Dated April 6, 1992. BACKGROUND This Environmental Action Memorandum describes the need for, and location of, proposed actions to remove unusable fuel products from the Drifting Ice Station Weddell (ISW), during the 1992 austral winter season. ISW is a joint research venture of the United States Antarctic Program (USAP) and the Arctic and Antarctic Research Institute (AARI) of Russia. The temporary station consists of a number of structures placed on an ice floe approximately two meters thick and one mile by two miles in area. Scientists are collecting oceanic and atmospheric data as the floe travels North in the Weddell Sea, roughly parallel to the Antarctic Peninsula, at an average rate of approximately 4.8 kilometers per day. ISW has on-site the following amounts of unusable fuel: þ Six hundred fifty (650) drums of JP-4 (a kerosene-based fuel), contaminated with water, rust and a presumed fungus. This fuel is staged at three caches separated by a few hundred yards. Most of the drums in each cache are standing rim to rim and are solidly frozen in .61 meters of ice, at their bases, and drifted to their rims in snow; þ One hundred (100) drums of usable gasoline that are frozen-in and buried similarly; and þ Thirty (30) 4,000-liter bladders of diesel fuel that are unusable at low temperatures due to waxing problems. All of the gasoline and one-third of the JP-4 was provided by the United States. The remainder of the fuel was provided by the Russians. All of the fuel was procured in Uruguay from ANCAP, the Uruguayan national petroleum company. Actual ownership, however, is ill-defined since all of the fuel was provided under the joint venture understanding. This fuel may have some residual value if returned to ANCAP, but any such value is negligible compared to the potential liability associated with recovery costs and adverse, potential environ- mental impacts if recovery is not accomplished. Due to the extreme accessibility problems of ISW there is a real possibility that the fuel cannot be recovered. In this case, burnoff of the fuel would be preferable to abandonment. USAP recognizes that the environmental consequences of not recovering the fuel could severe; and, current USAP planning focuses on recovery. The Russians initially agreed to assume responsibility for all retrograde waste (with the exception of the small amount of the radionuclide Carbon-14 generated during USAP-supported biology studies). A message was sent to Dr. Kornilov of the AARI on April 1, 1992, to call attention to the fact that the retrograde waste had been increased by several hundred drums of unusable fuel. No response has been received to date, and the Russians' position on this matter is unknown. It is assumed, however, that the Russians would be willing to help with the recovery and retrograde efforts, particularly if the United States agrees to disclaim any benefits from ownership or resale of the fuel. Nevertheless, the Russians have limited resources with which to help resolve this problem, except for manpower and transport- ation. The Environmental Officer posed a set of questions relating to the planning for the proposed fuel recovery project, and to the potentially affected environment. These questions were responded to by the civilian support contractor's Environmentalist and its Environmental Engineer on April 10, 1992; the questions and responses are shown below: Environmental Assessment Queries and Responses GENERAL: 1. What is the specific purpose of the proposed activity? To remove all contaminated, unusable and unused diesel, JP-4 and gasoline and the accompanying containers from Ice Station Weddell. The preferred alternative involves trans- ferring the contaminated and unused fuel from existing drums to new drums, voiding the old drums of any residual fuel as completely as is possible, and removing the emptied drums by mechanical means. The fuel and emptied drums would then be properly prepared for retrograde on the Russian research vessel the AKADEMIK FEDEROV (Federov). In addition, the diesel fuel contained in bladders would be dragged by Russian tractor to the awaiting ship where the fuel would be transferred on to the Federov. The bladders are constructed to withstand dragging across the ice in such a fashion. Also, the emptied bladders would be retrograded. The possibility exists that due to pack ice the ships (the USAP's Nathaniel B. Palmer and the Federov) would not be able to get close enough to the camp to complete the recovery of all fuel and drums as planned. In this case station recovery may be limited to helicopter operations. Under these circumstances it may be impossible to remove all cargo from the camp. Recovery activities would be according to the following priority order: 1) personnel; 2) scientific equipment; 3) valuable support equipment; 4) fuel, 5) other support equipment, and 6) empty drums. An attempt would be made to burn any fuel that could not be removed to prevent it from entering the ocean. What alternatives to the proposed activity have the Program and the Contractor considered? The contractor has considered several options which are summarized in Attachment A. Have probable impacts of all alternatives been considered by the Program and the Contractor? Please explain how. Yes (refer to Attachment A). The preferred alternative does involve potential impacts: spillage of fuel during transfer operations and drum excavation as well as air emissions should the residual fuel in the drums need to be flared prior to retrograde. However, in comparison to the other options listed on Attachment A, the propos- ed alternative is expected to entail the least impact. The Contractor believes that the proposed alternative also has the greatest potential for successful recovery of the fuel and drums. This is critical as an unsuc- cessful attempt has the potential to cause unacceptable environmental impact. The selection of the proposed recovery method has been largely driven by the constraints of the situation. This includes transportation of personnel and equipment, the lack of room at the camp to house and feed addition- al staff, the unknown behavior of the sea ice, and the short time frame in which preparations and recovery must occur. Persons involved with planning the station recovery believe the camp must be closed and removed before the ice floe reaches 65øSouth Latitude. Above this latitude ice occurs in smaller pieces, indicating it is likely the ice floe will break up. Should the chosen alternative involve potential impacts, how would these impacts be mitigated by the Program or the Contractor? Personnel transferring fuel from the buried drums to empty drums have been trained to be diligent and careful so as to minimize the potential for fuel spillage. Empty, new fuel drums would be staged to facilitate orderly transfer operations. Because fuel would be transferred from one container to another of the same size, there would be less potential for overfilling than when filling smaller containers from a large container. Other such actions to reduce fuel loss as placing drums in secondary containers during filling in case the new drum leaks, have been considered. However, the lack of time and capacity to deliver equipment, and the need to transfer fuel as quickly as possible, make including these actions in the proposed activity impractical. The relative impact of spilling some fuel compared to being unable to recover all or a large portion of the fuel justifies operating without certain fuel-loss control options. 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. An estimate of the cost of performing the action, including manpower, is included in Attachment B. The source of funds to cover the proposed fuel and drum recovery, and the consequential indirect impact on other USAP programs, remains to be determined by the Program. LAND USE AND PLANNING: 2. Where would the proposed activity be located, specifically? The ISW is located on pack ice in the Weddell Sea, Antarc- tica. As of April 6, 1992, the ISW was located at 680ø 51' South, 530ø 30' West and moving an average of 4.8 to 9.6 kilometers per day in a northerly direction. Have alternative locations been considered by the Program or the Contractor? If yes, which are they, if no, explain why. Not applicable. 3. How would any aesthetic impacts to the area from the proposed activity be handled by the Program or the Contractor? The main goal of the proposed activity is environmental protection. The sea ice on which the camp is located would eventually break up. The proposed fuel and drum recovery operation would preclude any negative aesthetic impact of petroleum spillage or of littering the ocean with 208 liter (55-gallon) drums. The proposed activity would have, therefore, a beneficial aesthetic impact. 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. Indirect impacts to the environment would be associated with one-time emissions from fuel-powered equipment used to transfer fuel and remove empty drums and bladders. Fuel- powered pumps certified for transferring flammable materials would be used in the in the transfer process. Fuel powered jack-hammers and a small tracked vehicle (Caterpillar #931) would be used to free the drums that are frozen in the ice. If the removed fuel is turned over to the Russians as planned its proper management would be out of the control of the United States Antarctic Program. Removing the fuel from the ISW may indirectly impact the environment in another location if the fuel is improperly transported or disposed. To minimize the potential that the fuel would be improperly disposed of the Contractor has contacted ANCAP to encourage the company to accept return of the fuel. 5. Would the proposed activity change the traditional use(s) of the proposed (or chosen) site? If yes, how; if no, why. No. The proposed activity represents an attempt to maintain the site in its original state. 6. Are the physical and environmental characteristics of the neighboring environment suitable for the proposed activity? If yes, explain why; if no, explain why. The proposed action would be taken to prevent contamination of the neighboring marine environment and to maintain its natural biological, chemical and physical characteristics. 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])? The proposed action is an effort to protect the environment and human health. However, the proposed action does present its own set of environmental risks such as accidental spil- lage of fuel during the recovery process or transport. Pre- cautions would be taken as much as is feasible to minimize these risks. Also, should the empty fuel drums require voiding (i.e., by flaring the remaining fuel content) prior to loading on the vessel, the flaring would be a temporary source of air emis- sions. This flaring would be done only if: 1) the drums are not recoverable; or, 2) the ship's captain would not allow the spent containers on board for health and safety reasons unless all residual fuel is removed. It is expected that the pumps would remove at least 90 percent of the fuel contained in the drums. 8. Would the proposed activity change ambient air quality at the proposed (or chosen) site? If yes, how; if no, why. Less than temporary or minor changes to the ambient air quality could be expected from the fuel-powered equipment and from emissions should any remaining fuel need to be flared. 9. Would the proposed activity change water quality or flow (drainage), at the proposed (or chosen) site? If yes, how; if no, why. No. The proposed action is an effort to protect water quality by removing the potential for risk of contamination. 10. Would the proposed activity change waste generation or management at the proposed (or chosen) site? If yes, how; if no, why. Yes. The proposed action would increase the amount of material to be retrograded. Transferring fuel into new drums, and excavating the drifted-in drums would introduce approximately twice the originally planned number of fuel drums at the ISW. Also, if it could not be returned to the original supplier, the contaminated fuel could constitute a waste that would have to be managed in an appropriate manner. 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. Yes. The action would increase energy demand by introducing additional fuel-powered equipment. Additional personnel would be required during the camp recovery operations to assist in the fuel transfer and drum removal, but they would be housed and fed on the ship. 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. Fuel transfer would have no effect on science. The majority of the recovery operations would occur in the last days before the camp is completely closed. Should the empty drums require flaring before ship loading, all research, including atmospheric, would have ceased. Additional staff would be sent to the camp to perform the recovery rather than requesting any assistance from the scientific contin- gent. Future scientific studies could be affected if the wastes fuels were not removed. 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. Yes. Fuel spilt during the transfer process could have transient impacts on seawater quality and marine life. If the fuel and drum recovery could not be completed as planned a known quantity of empty drums (or in a worst case, drums containing waste fuel) would fall eventually into the sea. Very small amounts of fuel spilt (i.e., those amounts that would prove impossible to fully recover) during the proposed activity are anticipated to have no more impact than petro- leum product leakage from the vessels operating near the ISW. 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)? The ice on which the camp is located may serve as habitat for assemblages of some antarctic bacterio-, phyto-, and zooplankton. HUMAN VALUES: 15. Would the proposed activity encroach upon any historical property of the site? If yes, how; if no, why. No. The ice floe exists temporarily; in time it would disintegrate. 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). Previously established plans have been set for removal by the Russians of all wastes from the camp. It is expected, therefore, that the fuel would be retrograded by the Russians. The equipment rented or purchased by the Con- tractor for use in recovering the fuel and drums would be retrograded from Antarctica on the Nathaniel B. Palmer unless the sea ice situation requires an emergency evacuation (i.e., limited to personnel). Finding The Environmental Officer, after reviewing the information presented above, believes that the proposed activity poses neither potentially minor nor transitory impacts to the antarctic environment. There are, in fact, anticipated environment- and future science-related benefits. The Program and the civilian Contractor are authorized to proceed with the proposed activity. A followup memorandum shall report on the outcome of this waste fuel recovery effort. Sidney Draggan cc: Environmental Engineer, DPP John Evans, ASA ATTACHMENT A Alternative Environmental Impacts Constraints 1. Pump fuel into empty drums; dig out existing drums; drag bladders to ship. The preferred alternative. Potential for spills during fuel transfer and drum excavation; air emissions if fuel in voided drums must be burned before transport. Ship may not get close enough to unload new, empty drums and to load old drums; labor and equipment must be supplied (including empty drums, pumps, jackhammers and Bobcat. 2. Dig out drums and retrograde: a) chip out. b) melt out. a) potential for punctures/spills. b) potential for fire; drums falling through ice. Ship may not get close enough to helo 750 drums; time (10 days spent offloading). a) labor; equipment. b) labor; equipment; energy for melter 3. Remove fuel, leave drums. a) transfer fuel to empty drums. b) combust fuel on site. Drums would become "litter"; residual fuel would enter ocean. a) spill potential. b) air emissions (< open burn). Equipment (pumps); labor. a) Obtaining empty drums (~100 on site). b) No large combuster available; fuel may ruin combuster. 4. Burn fuel in place. Air emissions; drums may fall through ice. Accessing drums. 5. Filter fuel and use on site. Replacement fuel has been supplied; helo pilots do not trust "bad" fuel; at least 750 filters required. 6. Do nothing. Drums would enter ocean; eventually fuel would leak. USAP policies, international marine oil pollution mandates. 7. Call in outside help (e.g., Coast Guard) to remove fuel and drums. Same as alternatives 1, 2 and 3. Camp cannot support staff increase, outside help would need to supply own food, lodging and equipment; time constraints. ATTACHMENT B Cost Estimates Component Costs Salaries; 4 @ $750/week for 7 weeks. $21,000 Travel and Deployment Costs; 4 @ $3200 $12,800 Equipment: Transfer Pumps; 3 @ $2000 = $ 6,000 Jack Hammers; 3 @ $1000 = $ 3,000 Drums (Used); 300 @ $4.00 = $ 1,200 Other = $ 800 $11,000 $11,000 Equipment Lease: Caterpillar #931; 2 months @ $5,000 $10,000 Shipping $ 3,200 Other $ 2,000 TOTAL $60,000