Title : Waste Staging Area-Fortress Rock Type : Antarctic EAM NSF Org: OD / OPP Date : December 24, 1992 File : opp93095 DIVISION OF POLAR PROGRAMS OFFICE OF THE ENVIRONMENT OFFICE OF SAFETY AND HEALTH 202/357-7766 MEMORANDUM Date: December 24, 1992 From: Environmental Officer, DPP Safety and Health Officer, DPP Subject: Environmental, and Safety and Health Action Memorandum (Establishment of Waste Management Staging Area at Fortress Rock Site) To: Facilities Engineering Projects Manager, DPP Environmental Engineer, DPP Environmentalist, ASA Commander, NSFA REFs: Final Supplemental Environmental Impact Statement for the U.S. Antarctic Program, Dated October 1, 1991. Initial Environmental Evaluation (Accelerated Implementation of Waste Management Actions at McMurdo Station, Antarctica), Dated October 17, 1991. Environmental Action Memorandum (Collection of Earth Fill Materials at McMurdo Station During the 1992-1993 Season), Dated December 1, 1992. AECOM Technology Corporation. 1992. Fortress Rocks Landfill Remediation Report. This joint Environmental, Safety and Health Action Memorandum describes the need for, and location of, proposed actions to establish a pre-retrograde, waste staging area at McMurdo Station's Fortress Rocks Site. The Environmental Officer and the Safety and Health Officer posed a set of questions relating to the proposed project, and to the potentially affected environ- ment. These questions were responded to by Antarctic Support Associates, Inc.'s (ASA) Environmental Engineer, Carol Andrews; Interim Safety Engineer, Jean Wardell; and McMurdo Station Waste Management Supervisor, Ted Patenaude on December 12, 1992; background information as well as the questions and responses are shown below: Background During the 1980-1981 season, a solid waste management area referred to as the Fortress Rocks dump was established at McMurdo Station to replace the old dump site along the shore of Winter Quarters Bay. The Fortress Rocks dump is contained on two sides by a chain link fence to control access and keep loose materials from blowing away. Waste was burned and buried at the site until it was closed at the end of the 1990-1991 season (Final SEIS USAP 1991). During the 1991-1992 season the Fortress Rocks dump was cleaned-up. This surface remediation included removal of exposed loose debris, leveling the area, and covering it with a few centimeters of fill material. Antarctic Support Associates (the civilian contractor) proposes to use a portion of the Fortress Rocks closed dump area to stage waste awaiting retrograde, beginning during the 1992-93 season. Environmental Assessment Queries and Responses GENERAL 1. What is the specific purpose of the proposed activity? The purpose of the activity would be to modify portions of the closed Fortress Rock Dump Site for use as a staging area for containerized waste awaiting retrograde via the annual resupply vessel and empty containers received from the vessel. Modification would include placing approximately 15.25 centimeters of fill material on the existing surface to prevent vehicle traffic from disturbing wastes that may, as yet, be buried at the site. What alternatives to the proposed activity have the Program and the Contractor considered? Alternatives considered include: 1) the proposed and preferred action; 2) identification of other locations; and, 3) the "no-action" alternative. Have probable impacts of all alternatives been considered by the Program and the Contractor? Please explain how. Impacts of the proposed activity include the potential for litter generation in the area during vessel unloading and loading. Counteractions to prevent litter generation is planned and would be implemented by the Contractor. Traffic on the ground surface of the former dump site may loosen existing, buried debris so that it is freed to migrate to the surface. A cover of fill material would be used as a cap over buried waste. This project would require approximately 765 cubic meters of fill material to provide a 10- to 15.25-centimeter cap. The impacts of fill material collection have been assessed by the Program and Contractor in separate documents. Adoption of the "no-action" alternative would increase the potential of adverse environmental impacts as the pre-retrograde, containerized wastes would accumulate in numerous unsecured areas around the station. In addition to creating eyesores, this would decrease the ability to maintain and manage the waste adequately. Also, the lack of a suitable staging area would hinder the cleanup and organization of an existing recycling area (Bldg. 340) where much of the containerized waste is currently stored. Should the chosen alternative involve potential impacts, how would these impacts be mitigated by the Program or the Contractor? Approximately 15.25 centimeters of fill material would be used to cover the proposed staging area to prevent any remaining debris within the former dump from being disturbed by waste staging activities. All wastes entering the area would be secured beforehand and containerized appropriately for within-station and vessel transport. ASA's Waste Management would be responsible for keeping the site's surface clean, organized, and free of debris. These measures are expected to counteract any potential environmental impacts. Have measures to assess the indirect costs of the proposed activity been identified or considered by the Program or the Contractor? Please explain how. Additional labor and energy costs may be incurred due to the distance from town associated with the Fortress Rock location. However, there may be a cost savings compared to the "no-action" alternative as wastes would be staged regardless of the alternative, and staging waste in one location rather than a number of locations around town may reduce the time required to load vessel containers. LAND USE AND PLANNING 2. Where would the proposed activity be located, specifically? The staging area would be within the fenced area of the former dump site located at Fortress Rocks. See attached map. Have alternative locations been considered by the Program or the Contractor? If yes, which are they; if no, explain why. "The Pass" at McMurdo Station would no longer be avail- able for waste staging as it has been proposed as the site of new fuel storage tanks. An area by Bldg. 183 (Interim Incinerator location) would be advantageous since it is close to the pier, however, there are no areas near Bldg. 183 that are adequate in size. The area adjacent to the south side of Bldg. 340, where recycl- ables and other waste are processed, is used by NSFA GSK and is not expected to be available for use by ASA Operations. The proposed staging area is also preferable to the alternative locations from an aesthetic point of view as it is not visible from town. 3. How would any aesthetic impacts to the area from the proposed activity be handled by the Program or the Contractor? All staging of waste containers would be performed according to a preplanned system of organization that would allow waste containers to be placed in neat rows. See attached schematic. Approximately 15.25 centimeters of fill material would cover the site to prevent existing debris from being freed from below the surface. 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 areas used for fill material collection would be disturbed. These borrow areas have been previously disturbed. A possible environmental impact may result from increased vehicle activity in the area. 5. Would the proposed activity change the traditional use(s) of the proposed (or chosen) site? If yes, how; if no, why. No, the area is a former dump site and presently is not used by the Program. 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 site is physically suited for the activity since it is relatively level already. Although the distance from town may increase the time required to transfer container- ized waste from processing locations (e.g., Bldg. 340, the Interim Incinerator) to a staging location, this distance keeps waste from being an eyesore in town and accessible to personnel. 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 site would be maintained by ASA Operations in a neat and orderly manner. Any debris that appears on the site would be removed by the Contractor. The purpose of the activity is to improve the station's waste management system. Water would be used to wet the roads and area, as necessary, to control dust. 8. Would the proposed activity change ambient air quality at the proposed (or chosen) site? If yes, how; if no, why. No, although some dust may be generated temporarily during fill material placement. Staging activities are not expected to impact air quality. 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 proposed fill material would make an existing low spot within the area level with its surroundings; and, this would not disrupt existing surface water drainage patterns. 10. Would the proposed activity change waste generation or management at the proposed (or chosen) site? If yes, how; if no, why. Yes, the activity would change waste management but not affect waste generation. It would enhance waste management. 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. Currently, the site is abandoned and has no activity. Additional waste transportation would be required to move waste to the site. No additional electrical power, personnel, or life support would be required. 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. Staging activities would be performed within the fenced area of the site and are not expected to have any adverse effects. 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. Waste would be properly contained to prevent litter generation. 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 wildlife habitat exists at the former dump site. Antarctic skua gulls were frequently sighted in the past when food-related wastes were available. HUMAN VALUES 15. Would he proposed activity encroach upon any historical property of the site? If yes, how; if no, why. No, the site exhibits no historic property. 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). Other than the fill material placed over the closed dump all materials placed in the staging area (triwalls, milvans) may be easily removed when the site is no longer used for waste staging as proposed. Finding The Environmental Officer, after reviewing the information provided above, believes that the proposed activity will pose less than minor and less than transitory effects to the environment near McMurdo Station. The proposed activity is expected to have beneficial impacts with respect to enhancement of waste management at the station. With adherence to U.S. Antarctic Program policy on earth fill materials collection and careful consideration of potential safety and health risks the proposed activity will improve the environment within McMurdo Station. The Safety and Health Officer joined in the review of this document as well as a document detailing the effectiveness of the clean up at the Fortress Rocks Site. From this informa- tion the Safety and Health Officer does not anticipate any significant health risks associated with the proposed activities (i.e., adding 10-15cm fill, then using site as a pre-retrograde waste staging area). The Safety and Health Officer noted that as long as the original fill "cap" is not disturbed in the site preparation and waste staging processes there should be no risks associated with any materials that may remain within the area's subsurface. Also, he noted that AECOM's findings indicate contaminant concentrations in the soil and air above the site are not of concern; and as long as the established surface is not disturbed, there is no expectation that those conditions will change. He concluded that he foresaw no reason that the proposed activity should be restricted for safety reasons. The Program and the Contractor are authorized to undertake the proposed actions. Sidney Draggan Harry Mahar Attachments