Title : Replcmnt. of Woodstove-Palmer Type : Antarctic EAM NSF Org: OD / OPP Date : November 30, 1992 File : opp93090 DIVISION OF POLAR PROGRAMS OFFICE OF THE ENVIRONMENT 202/357-7766 MEMORANDUM Date: November 30, 1992 From: Environmental Officer, DPP Subject: Environmental Action Memorandum (Replacement of Woodstove at Palmer Station) To: Safety and Health Officer, DPP Environmental Engineer, DPP Manager, Ocean Projects, DPP Environmentalist, ASA This Environmental Action Memorandum describes the need for, and location of, proposed actions to replace the wood burning stove at Palmer Station, Antarctica. The Environmental Officer posed a set of questions relating to the proposed project, and to the potentially affected environment. These questions were responded to by Antarctic Support Associates, Inc.'s (ASA) Environmental- ist, Terry Johnson; and Manager, Palmer Operations, Ann Peoples on November 3, 1992; the questions and responses are shown below: Environmental Assessment Queries and Responses GENERAL 1. What is the specific purpose of the proposed activity? To replace the existing wood burning stove with another that reduces significantly emissions that may lead to environmental impacts. What alternatives to the proposed activity have the Program and the Contractor considered? Three alternatives have been considered: Several types of stoves are being researched by the ASA Environmentalist; specifically those capable of meeting standards for such devices promulgated by the U.S. Environmental Protection Agency (USEPA); Eliminating the use of a woodstove; and The "no-action" alternative. Have probable impacts of all alternatives been considered by the Program and the Contractor? Please explain how. Yes. The stove chosen would be the best equipped for reducing potentially harmful air emissions. Eliminating completely the use of a woodstove would eliminate any associated emissions from being released to the environment. The no action alternative would result in the use of the existing stove. This stove was built prior to promulga- tion of current USEPA air emission standards for wood burning stoves and is considered obsolete. Should the chosen alternative involve potential impacts, how would these impacts be mitigated by the Program or the Contractor? The stove chosen for use at Palmer Station would be designed and certified to comply with the July 1990, particulate emission standards for non-catalytic com- bustor equipped stoves established by the USEPA. A catalytic combustor-equipped stove has been considered. Such a stove would have offered additional particulate emissions reductions. However, all distributors con- tacted recommended not using this type of stove due to the extra maintenance required to keep the catalytic combustor in working order. Substandard maintenance would present possible safety and health hazards by emitting carbon monoxide into the living area of station personnel. Have measures to assess the indirect costs of the proposed activity been identified or considered by the Program or the Contractor? Please explain how. Yes. The Contractor in considering whether a catalytic combustor-equipped wood burning stove would be more appropriate has determined that indirect costs in terms of maintenance for safety and emissions reductions were not appropriate. LAND USE AND PLANNING 2. What is the specific location of the proposed activity? The Dining Room Lounge at Palmer Station on Anvers Island, Antarctic Peninsula. Have alternative locations been considered by the Program or the Contractor? If yes, which are they; if no, explain why. No. The stove is a replacement for an existing item. 3. How would any aesthetic impacts to the area from the proposed activity be handled by the Program or the Contractor? None are anticipated. 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. None are expected. This proposed action would improve the environmental situation at Palmer Station. 5. Would the proposed activity change the traditional use(s) of the proposed or chosen site? If yes, how; if no, why? No. The proposed action provides for an environmentally- compatible replacement for an existing item. 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. Not only would the new woodstove continue to provide emergency heat to station personnel, it would increase the ambiance of the living area. 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])? Extensive research is being conducted prior to the selection of a new stove (an example of one stove under consideration is shown in Attachment I). Additionally, the only fuel that would be burned in the stove would be untreated wood. 8. Would the proposed activity change ambient air quality at the proposed or chosen site? If yes, how; if no, why? Yes, when used the new stove would not impact ambient air quality when compared to emissions from the old stove. 9. Would the proposed activity change water quality or flow (drainage), at the proposed or chosen site? If yes, how; if no, why? No. The stove's installation and use would not affect water quality or drainage patterns. 10. Would the proposed activity change waste generation or management at the proposed or chosen site? If yes, how; if no, why? No. However, if the stove or its use were banned there would be an increase in the amount of untreated wood waste requiring storage until retrograded from Palmer Station to Punta Arenas, Chile. In addition, residual ash from the woodstove would be retrograded from Antarctica in accordance with provisions of the Antarctic Treaty. 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? No. It would have no affect on facilities operations. 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. The proposed action would lessen the potential for environmental impact when compared with the existing stove. 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. Only untreated wood would be burned in the stove. 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. The proposed stove is housed in a pre-existing structure. Nonetheless, the vicinity of Palmer Station has a recognized and well-established assemblage of antarctic wildlife including marine mammals and birds, algae, lichens and mosses. Use of a wood-burning stove that reduces emissions to levels satisfying USEPA standards would improve ambient conditions for these wildlife. 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. 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. The old stove would be retrograded in a fashion consistent with existing U.S. Antarctic Program procedures as would the new stove when its useful life was complete. Finding The Environmental Officer, after reviewing the information presented above, believes that the proposed activity poses neither potentially minor nor transitory impacts to the antarctic environment near Palmer Station. There are recognized benefits related to appropriate use of clean waste wood for the benefit of the morale of station personnel. The contractor is authorized to proceed with the proposed activity. Sidney Draggan Attachment I Example of Non-Catalytic Woodstove Being Considered