Title : Storage Tanks-Marble Point Type : Antarctic EAM NSF Org: OD / OPP Date : October 23, 1992 File : opp93081 DIVISION OF POLAR PROGRAMS OFFICE OF THE ENVIRONMENT 202/357-7766 MEMORANDUM Date: October 23, 1992 From: Environmental Officer, DPP Subject: Updated Environmental Action Memorandum (Placement of Steel Fuel Storage Tanks at Marble Point, Antarctica) To: Safety and Health Officer, DPP Facilities Engineering Projects Manager, DPP Environmental Engineer, DPP Environmentalist, ASA Files (S.7 - Environment) REF: Environmental Action Memorandum (Placement of Steel Fuel Storage Tanks at Marble Point, Antarctica); Dated January 28, 1991. Background An Environmental Action Memorandum (EAM) for Placement of Steel Fuel Storage Tanks at Marble Point, Antarctica, was originally issued on January 28, 1991 by the Environmental Officer, NSF. Although the purpose of the proposed activity has not changed, the design of the proposed system has been modified. The Environmental Officer, NSF, believed circumstances surrounding the modifications to be of a major nature and called for this update. Specifically, the capacity of the proposed new fuel storage system has increased. Also, double-walled tanks would be used to supply the majority of the storage capacity. The most recent design is described in Attachment 1, the "10 Percent Basis of Design". Installation of the new tanks is planned for the 1993-1994 austral summer season. Antarctic Support Associates, Inc. (ASA), believes that the original January 28, 1991 EAM finding still applies. Information forming the basis for this update was developed by ASA's Environmental Engineer, Carol Andrews and Mechanical Engineer, Steve Bredl. Future modifications to the proposal contained in this EAM may require additional updating. GENERAL 1. What is the specific purpose of the proposed activity? The Naval Support Force Antarctica and ASA would replace fuel bladders with steel tanks. There would be four 95,000 liter (25,000 gallon) double-walled tanks and three single-walled 5,700 liter (15,000 gallon) tanks in a bermed, lined containment basin. What alternatives to the proposed activity have the Program and the Contractor considered? Three alternatives have been considered: 1) the proposed and preferred activity; 2) installing six 95,000 liter (25,000 gallon) double-walled tanks (and no single-walled tanks); and, 3) "no-action". Have probable impacts of all alternatives been considered by the Program and the Contractor? Please explain how. Yes. The impacts of the proposed activity include the following: 1) The total volume of fuel stored at the site would increase. This could increase the potential impacts resulting from a catastrophic failure of all or any of the containment systems. The likelihood of such fail- ure, however, is expected to be minute. 2) The potential for fuel release to the environment would be decreased due to the proposed double-walled tanks and associated containment system. 3) One or more traverses to Marble Point from McMurdo Station would be required to deliver the new tanks. 4) Earthwork, including excavation and berm construction, would be required to form the lined containment area. Fill material generated by the excavation would be used to create berms, reducing or eliminating the need to obtain fill from another location. Some blasting may be required, depending on the depth of permafrost and hardness of the rock. The bermed surface that the liner would be placed on must be free of large sharp rocks. To meet this specification some fill material may have to be scraped from a nearby location to pro- vide fines. If this is necessary an area already characterized by human activity and free of significant assemblages of wildlife (including mosses and lichens) would be used. The impacts of installing six rather than four double- walled tanks would be similar to the impacts associated with the proposed alternative. Overall cargo transport requirements would be greater since the single-walled tanks and liner material are already available at McMurdo Station. The tanks would still be placed within a lined area to provide containment of any spills resulting from leaks in pipes, overflow, or other causes that might not be contained by the double-walled system. The volume of the lined containment area could be less (approximately one-half), assuming the same standards applied to the proposed alternative were used (i.e., 25 percent of double-wall tank capacity and 125 percent of single-walled tank capacity). In this case, the containment area depth would be approximately .30 meters instead of .61 meters. The impact of the "no-action" alternative would be con- tinued fuel storage without secondary containment, increasing the potential for fuel loss to the environment. Also, the existing storage capacity is insufficient to allow science activities supported by the facility to continue in the event that annual re-fueling did not occur. Construction of new fuel storage facilities is necessary in the near future since the existing fuel bladders need replacement. Should the chosen alternative involve potential impacts, how would these impacts be mitigated by the Program or the Contractor? The Contractor would mitigate potential impacts associated with the construction work by keeping all vehicles in good operating condition so as to minimize emissions. An attempt would be made to wet the ground and fill material to control any dust generated by earthwork. Options con- sidered for dust control include obtaining sea water directly from the ocean through a temporary pipeline (the distance to the ocean is approximately 1.61 kilometers), melting snow for water, or obtaining water from a nearby lake. In the event of fuel spills, U.S. Antarctic Program (USAP) spill contingency and response plans would be followed. That plan conforms to the guidance provided by the Standing Committee on Antarctic Logistics and Operations, Subgroup on Oil Spill Prevention and Response, and approved by the Council of Managers of National Antarctic Programs. 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 temporary increase in personnel at Marble Point would increase life-support requirements and waste generation. Handling and processing of any construction related wastes would adhere to USAP policies. LAND USE AND PLANNING 2. What is the specific location of the proposed activity? The site is south of the present fuel bladder locations and approximately 31 meters away (see attached map). Have alternative locations been considered by the Program or the Contractor? If yes, which are they; if no, explain why. ASA considered areas near the present bladder location, since it is in a satisfactory location. The tanks need to be located in an area where helicopters would have easy access. 3. How would any aesthetic impacts to the area from the proposed activity be handled by the Program or the Contractor? Continuing attempts are being made to address aesthetic impacts associated with this and other activities at Marble Point. Marble Point is a heavily used helicopter re-fueling stop for the air support given to the field camps in the Dry Valleys area. It has been in use since 1956. During the 1989-1990 and 1990-1991 austral research seasons, Marble Point was the site of a concerted cleanup by components of the USAP. Management of the site after the subject improve- ments would highlight prevention of debris accumulation as has occurred in the past. 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 major impact would be improved control and containment of fuel. This impact is expected to have a beneficial effect at the site. 5. Would the proposed activity change the traditional use(s) of the proposed or chosen site? If yes, how; if no, why? No, the site would continue to be a refueling stop only. 6. Are the physical and environmental characteristics of the neighboring environment suitable for the proposed activity? If yes, explain why; if no, explain why. This is an excellent site for refueling. It is a relatively flat site, logistically well-suited for supporting research activities in the Dry Valleys. IMPACT AND POLLUTION POTENTIAL AND ENVIRONMENTAL MANAGEMENT 7. How has protection of the environment and human health from unnecessary pollution 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])? A berm would be installed and lined with 100-mil, high density polyethylene (HDPE), to contain spills. The containment berm would contain 25% of the total capacity of the double-walled, 25,000-gallon tanks and 125% of the total capacity of the 15,000-gallon, single-walled tanks, for a total of approximately 81,300 gallons. The bladders, which are not contained, would be removed. Workers at the site would be advised that any cleanup after work is their responsibility (and such performance will be monitored by Division of Polar Programs, and ASA Construction Engineering staff). All construction wastes would be retrograded to McMurdo Station. 8. Would the proposed activity change ambient air quality at the proposed or chosen site? If yes, how; if no, why? No. Temporary, minor emissions from construction equipment would occur. No overall change is anticipated. 9. Would the proposed activity change water quality or flow (drainage), at the proposed or chosen site? If yes, how; if no, why? Drainage would not change. The activity could change the water quality of runoff to the sea should a leak or spill contaminates the runoff. This should not occur provided that the berm system works as planned. The tanks would be elevated within the bermed area, so significant snow accumulation is not expected as wind-blown snow would pass beneath the tanks. 10. Would the proposed activity change waste generation or management at the proposed or chosen site? If yes, how; if no, why? During construction the population would temporarily increase, creating more human waste. These wastes would be retrograded to McMurdo Station. The existing four fuel bladders would be emptied as thoroughly as possible, cut open, swabbed clean, and packaged for retrograde (along with swabbing materials) according to a plan approved by the ASA Hazardous Materials Manager. 11. Would the proposed activity change energy production or demand, personnel and life support, or transportation requirements at the proposed or chosen site? If yes, how; if no, why? Yes. Transportation requirements would increase due to personnel working temporarily at the site and the moving of equipment. The demand for fresh water, food and waste transportation would be greater, temporarily. 12. Is the proposed activity expected to adversely affect scientific studies or locations of research interest (near and distant, short-term and long-term)? If yes, how; if no, why? It should not affect research during production, since the original flexible bladders would be in place while the tanks are being installed. The tank capacity would be 551,000 liters (145,000 gallons) after the tanks are installed. The current bladder capacity is 304,000 liters (80,000 gallons), so the station would have an additional 247,000 liters (65,000 gallons) of fuel. This would enhance scientific studies by allowing research transportation supported at Marble Point to continue even if fuel delivery did not occur for about one year. 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. Any catastrophic, accidental fuel leak or spill could have adverse effects. The new tank/berm system would be much safer than the present fueling arrangement. The required earthwork and liner placement might disturb isolated patches of moss, lichen or algae communities. Disturbance to significant assemblages of such antarctic wildlife are not anticipated as none are visibly evident at the site of the proposed work. 14. Does the site of the proposed activity serve as habitat for any significant assemblages of Antarctic wildlife (for example, mosses, lichens, antarctic birds or marine animals)? In the general area known as Marble Point, yes. According to New Zealand Antarctic Research Programme Report No. 1 (K321), January/February 1990, colonies of moss and algae are found there. At the site of the proposed work no such assemblages are evident. HUMAN VALUES 15. Would the proposed activity encroach upon any historical property of the proposed or chosen site? If yes, how; if no, why? No. Historically this has been a helicopter refueling 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 decommis- sioning of the activity been considered (and how)? None at the present time. The proposed tanks and liner would be completely removable in the event the proposed system must be decommissioned. Finding The Environmental Officer, after reviewing the information presented in this Environmental Action Memorandum update, still believes that the proposed activity, poses less than potential minor and less than potential transitory impacts to the environ- ment near Marble Point, Antarctica. The supplemental considera- tion given to the proposed project by ASA after the original Environmental Action Memorandum was completed has enhanced the environmental compatibility of the proposed project and decreased the potential for unnecessary environmental impacts to the area near Marble Point. There are recognized environmental, safety and science support benefits associated with completion of the newly proposed action. The Contractor and the Program are authorized to proceed with the proposed activity. Sidney Draggan Attachments 10 Percent Basis of Design Site Map Attachment 1 Marble Point Fuel Tank Design Marble Point, Antarctica 10% BASIS OF DESIGN I. Project Description and General Goals: Four, double-wall 25,000-gallon fuel tanks and three, single-wall 15,000-gallon tanks are to be installed at Marble Point. The purpose of this endeavor is to replace the fuel bladders presently used at Marble Point. This will increase the fuel capacity and take into account proper environmental issues and will decrease the chance of any major fuel spills at the site. Marble Point's main purpose is for re-fueling operations to support field sites in the dry valleys. A. Improved operations 1. The new tank system is designed with efficiency in mind. The new design will increase the overall fuel capacity of Marble Point by 65,000 gallons. Currently, the fuel bladders have a total capacity of 80,000 gallons. The proposed system will have a total capacity of 145,000 gallons. The tanks will be re-fueled on an annual basis. But, if for some unforeseen circumstance the tanks could not be re- fueled one season, the capacity would be sufficient to handle the load for the next season. Currently, Marble Point uses approximately 60,000 gallons of fuel per year, according to NSFA. B. Improved environmental standards 1. The proposed 25,000-gallon tanks will all be manufactured using double-wall construction. 2. The proposed 15,000-gallon tanks are currently at Scott Base and are not being used. These tanks will be cleaned and tested using API and NFPA specifications to assure they will work properly and efficiently and do not leak. 3. The new 25,000-gallon fuel tanks will be constructed using current NAVFAC, federal and state codes for fuel containment and will be U.L. listed. 4. All of the tanks will be set in a containment berm made from High Density Polyethylene. This berm will contain 25% of the total capacity of the double-wall, 25,000-gallon tanks and 125% of the total capacity of the 15,000-gallon tanks. This comes to approximately 81,300 gallons of overfill protection. The containment berm will in effect serve as tertiary containment for the double wall tanks. 5. The pumping station and piping will all be contained within the confines of the HDPE liner to further reduce the possibility of fuel spills contaminating the soil. C. General Maintenance 1. Only general preventive maintenance will need to be performed on the system. D. Cost Effectiveness 1. In most ordinary applications, low temperature steel fuel storage tanks last for many years and are not usually in danger of being punctured easily. A low temperature steel will not be affected significantly by low temperatures, as bladders are. Therefore, less money will be spent in the long run by not having to buy new bladders every few years. 2. A modern, environmentally safe system will reduce the costs of cleaning up a large fuel spill. II. Modifications/Changes To Site: A. A tentative location has been chosen for the new fuel tanks. See ASA drawing #05.31.16-MP-FUEL-C-01 for tank/berm location. This area will have to be excavated in such a manner to accommodate the system. Included in this outline are preliminary drawings and an outline specification of the proposed tank and berming system.