Title : Replacement of Fuel Cache-South Pole Type : Antarctic EAM NSF Org: OD / OPP Date : October 22, 1992 File : opp93080 DIVISION OF POLAR PROGRAMS OFFICE OF THE ENVIRONMENT 202/357-7766 MEMORANDUM Date: October 22, 1992 From: Environmental Officer, DPP Subject: Environmental Action Memorandum (Replacement of Emergency Fuel Cache at Amundsen-Scott South Pole Station, Antarctica) To: Safety and Health Officer, DPP Facilities Engineering Projects Manager, DPP Environmental Engineer, DPP Environmentalist, ASA Files (S.7 Environment) Background This Environmental Action Memorandum describes the need for, and location of, proposed actions for establishment of an emergency fuel cache at Amundsen-Scott South Pole Station. The Environ- mental Officer posed a set of questions relating to the proposed project, and to the potentially affected environment. These questions were responded to by the civilian support contractor's Environmental Engineer, Ms. Carol Andrews; and Supervisor for Facilities Engineering, Ms. Janet Philips, on July 22, 1992; the questions and responses are shown below: Environmental Assessment Queries and Responses GENERAL 1. What is the specific purpose of the proposed activity? The proposed activity would replace the existing emergency fuel supply at the station with two 38000 liter (10,000 gallon) stainless steel, double-walled fuel tanks. These tanks would be filled with JP-8 fuel. The existing fuel supply that now is contained in leaky drums (currently, leaks are contained) and small fuel bladders would be filtered and used as a fuel source for Jamesway heating. The new tanks would be filled near the existing emergency power plant directly from aircraft delivering new fuel to the station. What alternatives to the proposed activity have the Program and the Contractor considered? The following alternatives have been considered: þ Storage of 209 liter (55-gallon) drums in a lined pond was rejected as an alternative due to expected difficulties in rotation of the fuel supply, identification and cleaning of spills, and removal of snow drifts from around the drums; þ Use of single-walled fuel storage tanks emplaced in a lined pond was rejected as this would not provide a mobile system that could be relocated easily. Also, construction of a liner for a pond would prove difficult as the ambient temperature at the station often is below the minimum temperature for welding of synthetic liner materials; þ Use of nylon-reinforced urethane bladders within a lined pond was rejected as their operational rating extends only to -65§F; þ Use of fiberglass, carbon steel and plastic fuel storage tanks was rejected as none of the materials have been rated for use in environments similar to that of the South Pole; þ Use of aluminum, and nickel steel tanks was considered; their costs were much higher than equivalent strength stainless steel tanks and they less maintainable as they were non-mobile; and þ The "no-action" alternative was rejected due to the inadequacy of containment for the existing emergency fuel supply. Have probable impacts of all alternatives been considered by the Program and the Contractor? Please explain how. Yes. Alternatives 1-4 (as above) were seen to have a greater risk of causing fuel loss to the environment than the proposed alternative. In addition, alternative 1 would be less capable of ensuring a high quality fuel supply as the ability to reuse some of the existing emergency fuel supply (with replacement with new fuel) would be decreased. Alternatives 1-3 were seen as providing fewer opportunities for mobility than the proposed and preferred alternative. There are several actual and potential environmental impacts associated with the "no-action" alternative. There is evidence that a number of the existing fuels storage drums and 1900 liter (500 gallon) bladders are leaking. These existing containers date back to 1964. The fuel contained in them no longer is suitable for use at the emergency power plant. Failure to replace the existing fuel cache with a usable, secure emergency fuels supply could lead to loss of life. Under the proposed activity, Operations personnel at the station would be impacted by assuming the maintenance and filling functions of the new fuel tanks. Should the chosen alternative involve potential impacts, how would these impacts be mitigated by the Program or the Contractor? Drifting of snow would be minimized by placing the tanks on an elevated berm and aligning the tanks with the prevailing wind direction. Yearly snow removal would, as yet, be required. Overflow protection during filling would be accomplished by metering added fuel and by monitoring the volume of fuel in a given tank. Overpack containers would be available to place around old leaky drums as they are removed from the existing fuel supply. 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 occasional use of Operations personnel to rotate the fuel tanks would eliminate the problems associated with fuel aging as well as such labor-intensive activities as filtering before use of these fuels. LAND USE AND PLANNING 2. Where would the proposed activity be located, specifically? The fuel tanks would be located near the emergency power plant such that they can be filled directly from fuel delivery aircraft. In this location they would be easy to reach in an emergency. The tanks would be mobile and could be relocated in the future as necessary or desired. Have alternative locations been considered by the Program or the Contractor? If yes, which are they; if no, explain why. The location is dictated by aircraft and emergency accessibility. 3. How would any aesthetic impacts to the area from the proposed activity be handled by the Program or the Contractor? The steel tanks would be an aesthetic improvement over the existing emergency fuel storage that consists of a hodge- podge of old, dented and discolored drums and small fuel bladders. 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. The new emergency fuel cache would have a positive impact since it would allow fuel in the existing, substandard fuel cache of drums and small bladders to expended (with sub- sequent retrograde of old drums and bladders). 5. Would the proposed activity change the traditional use(s) of the proposed (or chosen) site? If yes, how; if no, why. The proposed tank site is in an area used as a construction camp and emergency camp; installation of the new fuel tanks would not affect this usage of land. 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 location is characterized already by a high degree of human activity. The tanks would not encroach upon any of the Restricted Use Sectors of the station. The stainless steel tanks are designed to withstand the extremely cold environment of the South Pole. 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 tanks are of the pre-manufactured type. There would be, therefore, no construction -related impacts to the environment. The vehicles that would be used to move the tanks are maintained regularly to minimize emissions. Double-walled tanks and careful filling procedures would be used to prevent fuel loss. Also, the tanks would be mobile. For example, they could be moved and used at a new, relocated summer camp. The tanks would not be one- time-use items. 8. Would the proposed activity change ambient air quality at the proposed (or chosen) site? If yes, how; if no, why. No. Under normal circumstances, there would be no emis- sions or fumes from the new 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. ambient temperature at the South Pole is such that there is no flowing water or drainage at the site. Blowing snow, however, is a constant occurrence. As the tanks have a solid foundation, snow drifting patterns would be affected by placement of the tanks and snow removal would be required. 10. Would the proposed activity change waste generation or management at the proposed (or chosen) site? If yes, how; if no, why. Yes. The retrograde of the old drums and bladders would add to the station's retrograde requirements. The proposed activity would not cause any permanent increase to waste generation rates. 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. The station's life support systems would be improved by the availability of quality fuel for emergencies. The transportation requirements would be increased slightly to occasionally move the fuel tanks to rotate the fuel. 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. Scientific research is not conducted in the vicinity of the proposed tank location. The proposed activity may benefit research as the mobile fuel tanks could be used to supply such remote science sites as the Cosmic Microwave Background Radiation Site. This would eliminate existing requirements for daily fuel delivery to such sites. 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 ecosystem surrounding the station would not be impacted by 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 ecosystem surrounding the station does not serve as habitat for any assemblages of antarctic wildlife. HUMAN VALUES: 15. Would the proposed activity encroach upon any historical property of the site? If yes, how; if no, why. No. While the emergency fuel supply is old, it is not of historic value to the site. 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). A clean up of the area around the old fuel cache should be considered and assessed once the old drums and bladders are removed. The Environmental Engineer for Antarctic Support Associates, Inc., in conjunction with the Environmental Officer, NSF, would assess the extent of contamination as well as potential environmental contamination resulting from the existing fuel cache. From such site characteriza- tion and assessment, remediation efforts might be recom- mended. Finding The Environmental Officer, after reviewing the information presented above, believes that the proposed activity, poses less than minor and less than transitory potential impacts to the environment near Amundsen-Scott South Pole Station, Antarctica. There are, in fact, recognized environmental and safety benefits associated with completion of the proposed action. The contrac- tor and the Program are authorized to proceed with the proposed activity. Sidney Draggan Attachment Site Plan