Title : Fuel Pumping Station-Palmer Type : Antarctic EAM NSF Org: OD / OPP Date : July 28, 1993 File : opp93069 DIVISION OF POLAR PROGRAMS OFFICE OF THE ENVIRONMENT 202/357-7766 MEMORANDUM Date: July 28, 1992 From: Environmental Officer, DPP Subject: Environmental Action Memorandum (Construction of a Fuel Filtering and Pumping Station at Palmer Station, Antarctica) To: Manager, Ocean Projects, DPP Facilities Engineering Projects Manager, DPP Environmental Engineer, DPP Files (S.7 - Environment) This Environmental Action Memorandum (EAM) describes the need for, and location of, a new Fuel Filtering and Pumping Station at Palmer Station, Antarctica. Antarctic Support Associates, Inc. (ASA) has proposed the action. The Environmental Officer posed a set of questions to ASA relating to the proposed project, and to the potentially affected environment. These questions were responded to by Tom Meyer, Assistant Project Engineer, ASA; Michael Papula, Mechanical Engineer, ASA; and Carol Andrews, Environmental Engineer, ASA, on July 6, 1992; the questions and responses are shown below. BACKGROUND At the request of the National Science Foundation, Jamestown Marine Services has conducted various studies related to fuel handling, containment, and spill contingency planning at U.S. Antarctic program (USAP) facilities in Antarctica. Work to upgrade fuels management at Palmer Station for environmental as well as safety and health purposes is an on-going effort. Based on recommendations contained in the Draft Oil Spill Prevention Control and Countermeasures Plan for Palmer Station, prepared by Jamestown Marine, installation of a new fuel transfer system between Palmer's two 473,000-liter (125,000-gallon) bulk fuel storage tanks is proposed by ASA. This new system would replace the current practice of using a mobile pump to transfer fuel between tanks. The new pump would also be used to mix fuel which may become gelled due to cold weather in order to make it liquid again. The new fuel system would be housed in a small (4.0 meter by 5.0 meter) building constructed on the existing grade using on-site stock materials, including pre-insulated panels. Stanchions of about 0.6 - 0.9 meters in height may be erected, if necessary, to hold power cables running approximately 61 meters between the new building and the station's power plant. Environmental Assessment Queries and Responses GENERAL 1. What is the specific purpose of the proposed activity? The purpose of the project is to replace an existing, outdated primary fuel filtering apparatus; and, to provide a permanent pumping system between the station's two bulk fuel storage tanks for daily as well as emergency fuel transfers. What alternatives to the proposed activity have the Program and the Contractor considered? The following alternatives have been considered: þ the proposed activity; and þ the "no-action" alternative. Have probable impacts of all alternatives been considered by the Program and the Contractor? Please explain how. Yes. If the transfer system is not built the station's personnel would continue to use the present method of transferring fuel. This method involves manually setting up a portable system for fuel transfer. Should the situ- ation arise wherein one of the bulk fuel tanks develops a leak, fuel would continue to be released into the envi- ronment until the portable system is set up to transfer the remaining fuel to the other tank. Palmer's bulk storage tanks are never more than half-full to allow such an emergency transfer to take place. The proposed system would allow fuel to be transferred quickly from one tank to the other. This system would work in conjunction with an alarm system which would signal a drop in fuel level in a tank. This ancillary signalling system is scheduled for installation during the Fiscal Year 1993 construction season. Aside from the positive impact of reducing the potential for fuel loss to the environment, the impacts of the proposed activity include generation of a small amount of construction debris. This debris will be managed by the contractor following established USAP policies for waste management. Should the chosen alternative involve potential impacts, how would these impacts be mitigated by the Program or the Contractor? As noted above, all construction debris would be properly packaged and retrograded in accordance with USAP waste management procedures. A spill response kit would be staged at the construction site and would remain in the completed fuel transfer system building to allow timely cleanup of any spills that might occur. 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 proposed activity would decrease the cost of station operation by reducing the number of personnel required to transfer fuel from two or three persons to one person. LAND USE AND PLANNING 2. What is the specific location of the proposed activity? The fuel filtering and transfer station would be located between Palmer Station's two 473,000-liter (125,000-gallon) bulk fuel storage tanks (see attached map). Have alternative locations been considered by the Program or the Contractor? If yes, which are they; if no, explain why. No. Because of the operational characteristics of the filtering and transfer system, it must be spaced equally distant from either tank, and it must be located near the existing fuel pipeline. 3. How would any aesthetic impacts to the area from the proposed activity be handled by the Program or the Contractor? As designed and planned, the proposed small building would be an aesthetic improvement over the conex box (small mil- van) which is used currently at the site to store fuel- transfer equipment. 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 proposed activity is not expected to have other indirect environmental impacts. The filter station would be housed in a small building and it would have appropriate fuel con- tainment capabilities to prevent fuel loss to the environ- ment in the event a leak were to occur at the filtering and transfer station. The containment volume of the building would be adequate to hold the volume of fuel contained in the pipes and the filter that would be between the shutoff valves to the two tanks. During fuel transfer personnel would be present and be able to turn off fuel flowing from a tank through the system in the event a leak develops in the transfer system. 5. Would the proposed activity change the traditional use(s) of the proposed or chosen site? If yes, how; if no, why? No. The filtering and transfer station location is in the proximity of the existing fuel storage tanks and pipeline. The area is not used for any other purpose. 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 ground surface at the proposed site is fairly level making it suitable for the placement of the proposed filtering and transfer system and its associated building. The building would protect the filter and pumps from the elements. 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 major goal of the filtering and transfer station is to prevent the loss of fuel to the environment. To achieve this the floor of the station would be a poured-in-place concrete containment pad sealed with an epoxy coating that would not degrade when exposed to fuel. A spill response kit would be staged in the building as well. Continued operation without the proposed filtering and transfer station improvements would present unnecessary threats to the environment. 8. Would the proposed activity change ambient air quality at the proposed or chosen site? If yes, how; if no, why? No. Only minor use of heavy equipment would be required for the project; emission of combustion products would be mini- mal, therefore. After construction is complete there would be no combustion at the site. Power for the pumps would be obtained from Palmer Station's power plant. Since fuels would be contained fully within the piping and filter units, and not exposed to the atmosphere, no unnecessary release of fuel vapors due to volatilization is expected. 9. Would the proposed activity change water quality or flow (drainage), at the proposed or chosen site? If yes, how; if no, why? No. There will be no modification to existing grade, which is flat. As the proposed activity would provide for enhanc- ed management and containment of fuels at Palmer Station, it has a high potential to reduce the risk of adverse impacts to freshwater and seawater quality. 10. Would the proposed activity change waste generation or management at the proposed or chosen site? If yes, how; if no, why? A small amount of construction debris would be generated and handled according to established USAP waste management pro- cedures. There would be no change in waste generation after construction is complete. 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? Power to operate the filtering station would be obtained from Palmer Station's power plant. There would be a slight increase in overall station power demand while the system is being operated. This would occur when fuel is delivered to the station, when anti-gel additives are mixed with the fuel, and when the day tanks are being refilled. The proposed system would replace the current mobile fuel powered pumping system with an electrically-powered one. 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? No. There is no scientific research occurring in the immediate area around the fuel tanks. Nonetheless, installation of the proposed system would decrease the likelihood of fuel spills at Palmer Station. This would represent a benefit to scientific studies that rely on relatively unperturbed study 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 system would be contained inside of a building on a containment pad. The pumps in this new system, unlike the fuel-powered pumps of the old system, would operate on electricity. 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)? No. antarctic wildlife rarely passes through the area and the area does not serve as a natural habitat. The area is characterized by a high degree of human activity. 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. There are no historic sites at Palmer Station. How- ever, Palmer Station is located within a new Multiple-Use Planning Area. 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)? As mentioned previously, there would be a continuing threat of unnecessary fuel loss to the environment if the system is not built. The site may be decommissioned and returned to its original condition by removing the building. Although some effort would be required to break up and remove the poured-in-place concrete base of the building, it would be possible. Finding The Environmental Officer, after reviewing the information presented above, believes that the proposed activity would pose substantially less than minor or transitory impacts to the antarctic environment. In fact, there are recognized environ- mental protection and safety benefits that would accrue from completion of the proposed project. The civilian support con- tractor is authorized to proceed with the proposed activity. Sidney Draggan Attachment (Map)