Title : Temporary Storage of Fuel-Contaminated Soil at McMurdo Station, Antarctica Type : Antarctic EAM NSF Org: OD / OPP Date : January 22, 1994 File : opp94015 REVIEW OF ENVIRONMENTAL DOCUMENT AND FINDING INITIAL ENVIRONMENTAL EVALUATION/ENVIRONMENTAL ASSESSMENT (IEE/EA) I have reviewed the attached environmental document (IEE/EA), including the finding and conclude that the information presented in the document is factual and a realistic representation of: The proposed action; The purpose of and need for the proposed action; Reasonable alternatives including the alternative of no action; Anticipated environmental effects based upon identified issues; and A complete listing persons consulted. The environmental document, focused on relevant issues and environmental effects, provides a clear basis of choice among alternatives which fulfil the purpose of and need for the proposed action. /s/ Jane Dionne Dr. Jane Dionne January 22, 1994 Acting Environmental Officer Office of Polar Programs National Science Foundation /s/ Robert S. Cunningham Mr. Robert S. Cunningham January 22, 1994 NEPA Compliance Manager Office of Polar Programs National Science Foundation ENVIRONMENTAL DOCUMENT AND FINDING OF NO SIGNIFICANT AND NOT MORE THAN MINOR OR TRANSITORY EFFECT Temporary Storage of Fuel-Contaminated Soil at McMurdo Station, Antarctica. I. Finding The National Science Foundation (NSF) has prepared an Initial Environmental Evaluation (IEE) and an Environmental Assessment (EA) as a combined document, for the temporary storage of fuel-contaminated soil at McMurdo Station, Antarctica. A temporary soil storage facility will be used to store fuel-contaminated soil at McMurdo Station until a decision is made, with appropriate environmental review within three years, to either treat and re-use fuel-contaminated soil at McMurdo Station or remove such soil from Antarctica. Fuel-contaminated soil is to be recycled or removed from Antarctica within three years of contamination pursuant to the Antarctic Conservation Act (ACA). Based on the analyses in the environmental document (IEE/EA), the NSF Office of Polar Programs (OPP) has determined that the proposed action, implementation of Alternative B is not a major federal action which would have a significant effect on the human environment, within the meaning of the National Environmental Policy Act (NEPA) of 1969 nor is the action one which would have a more than minor or transitory effect on the antarctic environment within the meaning of the NSF implementing requirements for the Protocol on Environmental Protection in Antarctica. The selected alternative, B, enables fuel-contaminated soil to be stored in a cost effective manner with minimal environmental impact. Fuel- contaminated soil, temporarily stored at the Fortress Rock Waste Processing Center, will be placed in a containment area, covered to prevent water from entering the soil, and monitored. The temporary storage of fuel-contaminated soil is consistent with the NSF's efforts to remediate accidental spills of fuel and protect the antarctic environment. /s/ Erick Chiang _____________________ Mr. Erick Chiang January 22, 1994 Manager, Polar Operations Office of Polar Programs National Science Foundation 4201 Wilson Boulevard Arlington, Virginia 22230 II. Purpose and Need for the Proposed Action The National Science Foundation (NSF) proposes to temporarily store fuel-contaminated soil for future decontamination and reuse at McMurdo Station, Antarctica or retrograde to the United States. The contaminated soil would be stored in a contained area at McMurdo Station for no more than three years (Antarctic Conservation Act Waste Regulations, 45 CFR 671.3, storage limitation), while soil decontamination technologies and equipment are assessed, and if determined feasible, appropriate equipment procured and installed at McMurdo Station. There are currently approximately 153 cubic meters of fuel-contaminated soil stored in 770, 208-liter drums. Another 153 cubic meters of similar soil is stored in a temporary, bermed storage area with a water proof liner. There would be a maximum of 700 cubic meters of fuel-contaminated soil stored at the proposed storage area at any one time. To minimize the potential for future migration of contaminants, the NSF removes and contains fuel-contaminated soils in drums or open containment areas. It may be feasible and reasonable to remove the fuel from contaminated soils through treatment. Such methods are now under investigation by the NSF. A temporary storage area is needed because the opportunity to beneficially reuse the soil, if it can be cleaned, will be lost if the current inventory of drummed, fuel-contaminated soils are retrograded to the United States. A shortage of 208-liter drums may hinder fuel spill remediation this season. Cleanup of a fuel spill near Tank D-6 at McMurdo Station in September 1993 required use of a large portion of the stock of open-top drums. Currently, there are an inadequate number of empty drums available to contain fuel- contaminated soils from a large spill, should another occur before the drum stock is resupplied. The NSF has taken action to minimize accidental fuel spills and reduce their impact. Overfill alarms on fuel storage tanks have been installed, rubber gaskets in pipelines have been replaced with durable Garlock gaskets, secondary containment systems for storage tanks and fuel transfer systems are in place, and a fuel spill prevention program for United States Antarctic Program (USAP) participants has been initiated. Information regarding accidental releases of fuels and steps taken to minimize such releases is available in the "Master Permit Application and Waste Management and Minimization Operation Plan." During consideration of the proposed action, the following issues were identified: 1. Fugitive dust emissions; 2. Volatilization of petroleum products during soil handling and storage; and 3. Release of contaminants to water resources. III. Alternatives Alternative A. No Action. In this alternative, the NSF would continue to store fuel-contaminated soil in 208-liter drums to be retrograded to the United States. Alternative B. Construct a lined, bermed storage facility in the Fortress Rock Waste Processing Center. In this alternative, a storage area for fuel-contaminated soils would be located in the Fortress Rock Waste Processing Center (see Attachment 1). The area is located adjacent to the snow dump and just below the metal baling area. The area has a slope of 10 to 15 degrees. The site is not visible from most areas of the station, including "downtown." A bermed containment area approximately 15.24 meters by 15.24 meters, lined with Hypalon and designed to contain liquids which may seep out of the soil, would be constructed before any contaminated soil would be stored. Before the station closes for the winter season, the soil would be covered with another liner to prevent wind erosion, reduce volatilization of hydrocarbons, and prevent snow from mixing with the soil. The surface liner would be covered with clean fill, cabled, and anchored by rods to protect it from wind damage. When the facility is no longer needed, the surface and subsurface liners would be removed and the site would be returned to its original condition. If it proves to be damaging to the site to remove anchor rods, they may be cut off at the soil surface and left at the site. IV. Environmental Effects and Mitigating Measures A. Fugitive dust emissions. Both alternatives have the potential to create fugitive dust emissions created by heavy vehicle movement. In addition, some grading and placement of approximately 190 cubic meters of clean fill material is required for Alternative B to prepare a smooth working area for vehicles. This work may also create dust emissions. To minimize dust emissions, brine water would be used as necessary during regrading activities and periods of high truck traffic (to wet non- contaminated soil only). When fuel-contaminated soil is transported from one place to another via open truck, there is a potential for dust emissions from the blowing of soil in the truck by the wind. If the soil is moist, as is typically the case with fuel- contaminated soil, dust emissions are expected to be minimal or non-existent. Trucks would be routed away from populated areas such as the dorms and galley to minimize annoyances due to dust emissions and odors. As stated earlier, fuel-contaminated soil stored at the site would be covered in winter to prevent contaminated soil from becoming airborne, being deposited in uncontaminated areas and, subsequently inhaled by McMurdo residents. It would also prevent snow from accumulating on the soil. B. Volatilization of petroleum products during soil handling and storage. Petroleum products contain volatile contaminants; the type and quantity depend on the type of fuel. Volatiles may be released from the surficial soil during transport and storage. The quantity of volatiles released from exposed soil would be greater than that released by soil stored in sealed drums. However, the release of small quantities of volatiles expected from the storage area, would not harm workers or pose a health risk to McMurdo Station residents. Personnel working around petroleum products during soil handling and storage would follow all safety guidelines established by the Antarctic Support Associates Safety Engineer to minimize exposure to volatiles released by fuel- contaminated soil. C. Release of contaminates to water resources. The storage site in Alternative B is located near a surface water drainage ditch. If contaminated liquid were accidentally released, it could enter surface water drainage and eventually be transported to Winter Quarters Bay. Alternative A would have little likelihood of contaminated liquid entering surface water drainage, if the drums are kept in good condition and monitored for leaks. To prevent release of contaminated liquids to the environment in Alternative B, the lining of the storage area would be checked after installation and once per week thereafter. To protect the liner, at least 30.5 cm of contaminated soil would be placed over the liner before vehicles drive on to the storage area (see Attachment 2). To minimize the potential for leakage, any liquid which drained from the contaminated soil would be diverted to a depression within the lined area and pumped into drums. D. Short-term effects The short-term effects of storing fuel-contaminated soil in a bermed storage facility for future recycling or retrograding would be the elimination of the demand for drums to be used for this purpose. These drums are in short supply at McMurdo Station. Also, the temporary storage of soils will enable the NSF to evaluate appropriate treatment methods for cleaning and reusing soils which may have been contaminated by fuel spills. E. Long-term and cumulative effects Construction and use of the soil storage area will improve the capacity of the USAP to remediate fuel-contaminated soils. In the long term, this increased capacity will improve the environmental quality of McMurdo Station. V. Consultation With Others Antarctic Support Associates: Ms. Robin Abbott Science Support Coordinator Ms. Carol Andrews Environmental Engineer Mr. Jim Chambers Deputy Project Director, Continental Systems Mr. Pat Haggarty Manager, Construction Mr. Charlie Hanson Heavy Equipment Operations Mr. Wiley Smith Planner Mr. Ted Patenaude Solid Waste Manager National Science Foundation - Office of Polar Programs Mr. Erick Chiang Manager, Polar Operations Mr. Robert S. Cunningham NEPA Compliance Manager Dr. Jane Dionne Acting Environmental Officer Mr. Peter Karasik Assistant Compliance Manager Attachment 1: McMurdo Station site map Attachment 2: Sketch of soil containment area design