Title : New Storage Tanks-McMurdo Type : Antarctic EAM NSF Org: OD / OPP Date : January 06, 1993 File : opp93100 DIVISION OF POLAR PROGRAMS OFFICE OF THE ENVIRONMENT OFFICE OF SAFETY AND HEALTH 202/357-7766 MEMORANDUM Date: January 6, 1993 From: Environmental Officer, DPP Safety and Health Officer, DPP Subject: Environmental, and Safety and Health Action Memorandum (Installation of New Bulk Fuel Storage Tanks in the Pass, McMurdo Station) To: Facilities Engineering Projects Manager, DPP Environmental Engineer, DPP Environmentalist, ASA Commander, NSFA Robert Lugar, Idaho National Engineering Laboratory REFs: Environmental Action Memorandum (The Hut Point Initiative at McMurdo Station, Antarctica), Dated October 14, 1992. Environmental Action Memorandum (Collection of Earth Fill Materials at McMurdo Station During the 1992-1993 Season), Dated December 12, 1992. This Environmental Action Memorandum describes the need for, and location of, proposed actions to install two bulk fuel storage tanks (Bulk Fuel Tanks "J-6" and "J-7" with secondary containment berms McMurdo Station, Antarctica. 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; Interim Safety Engineer, J. Wardell; and Mechanical Engineer, S. Bredl on January 4, 1993; the questions and responses are shown below: Environmental Assessment Queries and Responses GENERAL 1. What is the specific purpose of the proposed activity? The purpose of the activity is to install two 1,892,500 liter (500,000-gallon) fuel storage tanks at McMurdo Station's existing tank farm located east of Observation Hill in the area known as "The Pass." The proposed actions would include construction of two secondary containment berms in addition to installing the tanks. What alternatives to the proposed activity have the Program and the Contractor considered? Alternatives include the proposed and preferred actions and the "no-action" alternative. No other actions or locations could be identified as suitable alternatives. Have probable impacts of all alternatives been considered by the Program and the Contractor? Please explain how. Yes. Impacts of the project as proposed include an increase in the potential for fuel spills and leaks due to the addition of fuel storage tanks and associated piping. Impacts from leaks and spills from the proposed storage tanks would be minimized by adherence to the U.S. Antarctic Program's (USAP) continually improving efforts at oil spill contingency and countermeasures training and implementation of spill response planning and procedures as well as the construction of secondary containment systems (i.e., in this case, earthen berms). There is, however, the potential that a berm liner may rupture or tear and allow leaking fuel to enter the subsurface of the berm. Additional impacts include dust emissions due to fill-moving operations during construction of berms, alterations to existing surface water drainage and snow drifting patterns, and the impacts associated with fill gathering. Fuel fire and explosion hazards are an inherent danger with fuel storage facilities. As a result, the proposed tanks would be located at an existing tank farm outside of McMurdo Station, away from the population center. If the "no-action" alternative were selected, the station would be operating with an insufficient fuel capacity to assure personnel safety and health. Two fuel storage tanks were removed from Hut Point during the previous austral summer season (1991-1992). The last remaining tank on Hut Point is to be removed in the near future. Removal of these tanks has reduced the station's fuel storage capacity. If the proposed tanks are not installed the fuel storage capacity of the station may limit the amount of activity, including scientific research, that the station can support. Should the chosen alternative involve potential impacts, how would these impacts be mitigated by the Program or the Contractor? The contractor would take the following steps to mitigate any impacts of the proposed activity: 1) Secondary containment would be provided for the two tanks. This would consist of a berm with a high-density polyethylene (HDPE) liner constructed to hold 125% of the of the combined tanks' volume. 2) To ensure that the liner is free of leaks the contractor would follow standard liner installation practices. This would include ensuring no sharp objects are placed on or below the liner and testing liner seams for leaks and weld strength. A 30 centimeter (12 inch) protective layer of soil would cover the liner. The contractor would inspect the liners for tears and punctures visually as part of annual inspections and would repair the liner as necessary. 3) Localized drainage patterns may be altered, but overall drainage would remain unchanged. 4) Blowing snow may accumulate in the bermed areas. The contractor, as part of maintenance of the fuel storage and distribution system, would inspect the containment systems in October and February at a minimum. Snow accumulated over the winter would be removed carefully to maintain the capacity of the containment system. Snow or water that accumulates inside of the berms during the summer would be swept or pumped out as necessary. 5) To minimize dust emissions and maximize compaction the contractor would wet earth fill material using a water truck. Have measures to assess the indirect costs of the proposed activity been identified or considered by the Program or the Contractor? Please explain how. The inspection and maintenance activities discussed above would increase the workload of the contractor's maintenance department. LAND USE AND PLANNING 2. Where would the proposed activity be located, specifically? The tanks would be installed southeast of existing Bulk Fuel Tank "J-5" in The Pass. See attached figure. Have alternative locations been considered by the Program or the Contractor? If yes, which are they; if no, explain why. Due to fire and explosion hazards associated with bulk fuel storage, tank locations should be outside of population centers. Hut Point is not a desirable site since: 1) the elevation of that site is below much of the station such that fuel must be pumped rather than gravity fed from tanks at that location; 2) fuel spilled on Hut Point may be more difficult to control; and, 3) placing new tanks on Hut Point would be counter to the Hut Point Initiative. Other sites where bulk fuel tanks are currently located, such as along the hill north of Winter Quarters Bay, would require extensive earthwork and placement of earth fill material to create a suitable base and secondary containment area for the proposed tanks. 3. How would any aesthetic impacts to the area from the proposed activity be handled by the Program or the Contractor? The contractor would maintain the construction site in a neat and orderly manner pursuant to USAP policy. Although the storage tank and containment systems may not be considered attractive, they are situated at an existing tank farm having the same appearance; and they serve an environmentally beneficial and safety purpose. 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. An increase in the number of fuel storage tanks may increase the amount of fugitive hydrocarbon emissions to the atmosphere. Increases in fuel capacity could allow for increases in other activities. With increased attention to fuel conservation measures, USAP intends to allow increases only in those activities necessary to support scientific research of high quality. Such activities might include increases in vehicle activity and higher electrical energy consumption. Increases in air emissions from vehicle and generator exhaust would be a result of increased fuel consumption. However, the USAP and its military and civilian contractors are committed to following the energy conservation measures imposed due to the fuel shortages experienced during the 1992-1993 austral summer season, and to work towards increased economy of fuel use in the future. Vehicle activity at the site (a storage area in past seasons) itself may be reduced since materials would no longer be stored at the proposed tank site. The change in traditional use of the site would require less vehicle and worker activity once tank and berm construction is complete. Materials for the new tanks have been stored at the station for a number of years. Sand blasting of the plate steel used to construct the tanks would be done to remove any rust. A containment and recovery system for collecting and reusing the blasting particles would be employed by the Contractor. Berm construction would require a large quantity of fill. Fill gathering would require blasting and removing rock from a quarry. Fines would be obtained by scrapping material off the surface over large areas. Fill is currently being collected for the construction of berms at existing fuel storage tanks. The impacts of these activities have been addressed in a separate document regarding McMurdo Station fill-gathering activities for the 1992-1993 austral season. The storage area at "The Pass" for wood wastes that are densified and retrograded would have to be moved to make room for the new tanks. Moving the wood pile would require use of personnel, and equipment. 5. Would the proposed activity change the traditional use(s) of the proposed (or chosen) site? If yes, how; if no, why. Yes. The site has been used previously for storing and staging of materials transported by the annual supply vessel. A portion of the site is also used for storing wood waste awaiting retrograde. 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 area around the tanks in "The Pass" is generally flat and suitable for tank and containment construction. The area is characterized by a high degree of human activity and is, therefore, suitable for installation of manmade structures. 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])? Secondary containment systems would be constructed to restrict migration of any fuel spills from the tanks. The containment systems consist of lined, bermed areas designed to hold 125% of each tank's volume. The liner is constructed of polyethylene fabric, designed for this type of containment. In accordance with USAP policy the proposed containment berms have been designed to minimize the amount of fill material required. The use of a common berm between the two containment areas and use of the base of Observation Hill to construct the berms would reduce the amount of fill material required. Sand blasting of the steel for tank construction would be required. The blasting abrasive would be collected and reused to minimize dust and waste production. 8. Would the proposed activity change ambient air quality at the proposed (or chosen) site? If yes, how; if no, why. Yes. Ambient air quality may be effected, presumably to a very small degree, by fugitive emissions. As with the other fuel storage tanks in "The Pass", some volatilized hydrocarbons would escape the storage vessels and associated appurtenances. Air quality would be temporarily affected by dust and exhaust emissions from earthmoving equipment used during construction. 9. Would the proposed activity change water quality or flow (drainage), at the proposed (or chosen) site? If yes, how; if no, why. Surface water drainage patterns would be altered on a localized level as water would be directed through ditches around the berms. Similar alterations have already been performed as part of the construction of containment berms for the existing storage tanks and are considered neces- sary. The overall drainage patterns of the site would not change. 10. Would the proposed activity change waste generation or management at the proposed (or chosen) site? If yes, how; if no, why. No, neither the current or proposed use of the site generates waste material. However, if an accidental release of fuel from a tank occurred then the fill material placed over the liner within the bermed area would eventually be retrograded or treated. 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. Tank and containment area construction would increase temporarily the personnel demand at the station. The Contractor proposes beginning construction of the tank pads and berms during January and February 1993 while the site is free of snow and earthwork may be more easily performed. Tank construction is scheduled for the 1993-1994 austral summer season. 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 long-term, adverse effects on scientific studies are expected. A positive impact may occur: the increase of fuel storage capacity would lessen the potential for fuel shortages, that have had adverse effects on a number of science projects during the 1992-1993 austral season. Any dust generated at the site during construction should not affect experiments at the Cosmic Ray Laboratory. The contractor would coordinate with Idaho National Engineering Laboratory to ensure the activity does not interfere with ambient air quality monitoring. 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. The pollutants that may be generated during construction would be limited to dust and pollutants contained in exhaust from the construction equipment. The quantity of these pollutants would be minimized to the extent possible and is not expected to affect surrounding ecosystems. In the event of a failure of one or both of the proposed tanks and a structural failure of the secondary containment system, a large quantity of fuel 1,892,500 liters (500,000 gallons) per tank could potentially be released to the environment. Although the potential impact of such a large of a spill could be devastating to the terrestrial and marine environments, the likelihood of catastrophic failure of both the tanks and secondary containment system is highly unlikely. 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. Wildlife in the area is limited to occasional visits by skuas. There are no known skua nesting grounds in the area immediately around "The Pass" where the tanks are planned to be installed. HUMAN VALUES 15. Would he proposed activity encroach upon any historical property of the site? If yes, how; if no, why. No, although the base of Observation Hill would serve as part of the containment system for the storage tanks. Since the tanks would be situated close to the hill as the other tanks currently are, use of the base would not change the aesthetics or recreational use of the hill. The side of the hill in the vicinity of the proposed activity has been previously modified earthwork. 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, associated piping and containment systems would be completely removable. 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 storage and management at the station. With adherence to U.S. Antarctic Program policy on earth fill materials collection and careful consideration of potential safety and health risks the proposed activity will improve the environment within McMurdo Station. The Safety and Health Officer joined in the review of this proposed action. From the information presented above, the Safety and Health Officer concurs with the finding of the Environmental Officer, with the condition that the design, installation and maintenance of the fuel tanks, secondary containment berms, and liners conform with sound engineering practice; and, that construction is in accordance with pertinent Occupational Safety and Health Administration construction standards. The Program and the Contractor are authorized to undertake the proposed actions. Sidney Draggan Harry Mahar Attachment