Title : Environmental Document:Master Permit Application for Waste Management Type : Antarctic EAM NSF Org: OD / OPP Date : March 7, 1994 File : opp94018 National Science Foundation Office of Polar Programs ENVIRONMENTAL DOCUMENT AND FINDING OF NO SIGNIFICANT AND NOT MORE THAN MINOR OR TRANSITORY ENVIRONMENTAL IMPACT MASTER PERMIT APPLICATION for MATERIALS AND WASTE MANAGEMENT AND WASTE DISPOSAL March 2, 1994 FINDING The National Science Foundation (NSF) has prepared an Initial Environmental Evaluation (IEE) and an Environmental Assessment (EA) as a combined environmental document, for the issuance of a waste management permit to Antarctic Support Associates (ASA) and the Naval Support Force, Antarctica (NSFA) governing the use of materials, waste management practices, and environmental releases in support of the United States Antarctic Program (USAP) in Antarctica. Based on the analyses in the environmental document (IEE/EA), the NSF Office of Polar Programs (OPP) has determined that implementation of Alternative 2 is not a major federal action which would have a significant effect on the human environment, within the meaning of the National Environmental Policy Act (NEPA) of 1969 nor is the action one which would have more than minor or transitory effect on the antarctic environment, within the meaning of the NSF's assessment procedures described in 45 CFR Part 641. The selected alternative, 2, provides for the issuance of a waste management permit with conditions to the permit applicants, ASA and NSFA. The measures outlined in the permit documents would achieve reductions in pollutant releases to the antarctic environment through revised operational procedures and facility improvements. Alternative 2 is consistent with the NSF's efforts to promote scientific investigations, while protecting the antarctic environment. During review of the permit application, a broad range of environmental issues were identified. Areas of concern include fuel storage and distribution systems, wastewater management, the development of long-term environmental planning documents, and contractual changes to improve operations. While some of these topics are addressed in the permit application documents, NSF intends to further advance environmental improvements through additional measures which will be addressed in other environmental planning and decision documents which are under preparation at NSF. /s/ Cornelius W. Sullivan March 7, 1994 Dr. Cornelius W. Sullivan Date Director, Office of Polar Programs National Science Foundation 4201 Wilson Blvd. Arlington, Virginia 22230 INITIAL ENVIRONMENTAL EVALUATION AND ENVIRONMENTAL ASSESSMENT MASTER PERMIT APPLICATION for MATERIALS AND WASTE MANAGEMENT AND WASTE DISPOSAL I. PURPOSE AND NEED The National Science Foundation (NSF) proposes to grant a master permit to govern the management of materials, wastes and environmental releases associated with the U.S. Antarctic Program (USAP) in Antarctica. The permit would incorporate the management procedures and facility modifications presented in the permit application as well as supplementary conditions to assure that adequate performance oversight and reporting occurs and that NSF's management direction on incineration of wastes is clarified. The proposed term of the permit is August 15, 1993 to September 30, 1994. The joint permit applicants are the contractor for the USAP, Antarctic Support Associates (ASA), and the U.S. Naval Support Force, Antarctica (NSFA). ASA and NSFA will be active in Antarctica during the requested term of the permit. The proposed action complies with the Antarctic Conservation Act (ACA, Public Law 95-541) as described in implementing regulations at 45 CFR Part 671 (Waste Regulation). It is unlawful for any U.S. citizen to use or release certain substances in Antarctica without a permit issued by NSF (45 CFR Part 671, Waste Regulation). The regulations require that the permit application include, among other things: 1) A description of the types, expected concentrations and volumes of wastes and designated pollutants to be released in Antarctica; 2) The nature and timing of releases; 3) Provisions for waste management, including, without limitation, plans for waste reduction, minimization, treatment, processing, recycling, storage, transportation, and disposal; 4) Provisions for training and educating personnel to comply with waste management requirements and procedures; 5) Other provisions for minimizing and monitoring the environmental impacts of proposed operations and activities; 6) A description of the types, expected concentrations and volumes of designated pollutants to be used in Antarctica; 7) The nature and timing of such uses; 8) The method of storage of designated pollutants; and 9) A contingency plan for controlling releases in a manner designed to minimize any resulting hazards to public health and the environment. Human activities in Antarctica can cause environmental releases of a variety of materials and wastes. When issued, the waste management permit approves the proposed waste management procedures and environmental controls described in the permit application documents. The regulation of wastes and designated pollutants through the permitting process is one of several oversight mechanisms used by the NSF to control and limit the environmental impact of the USAP. Issuance of the master permit will improve the management of wastes and the quality of the antarctic environment. In considering approval of the master permit, five issues were identified. These issues identify opportunities to improve the performance of permit requirements and further reduce the environmental impact of the USAP. These issues are: . Reduction of accidental releases to the antarctic environment; . Reduction of planned releases to the antarctic environment; . Waste minimization, recycling and removal; . Compliance with laws, regulations and international agreements; and . Planning for the environment and enforcement. This document is a combined Initial Environmental Evaluation (IEE) and an Environmental Assessment (EA) prepared in accordance with the requirements of 45 CFR Part 641, and those of the National Environmental Policy Act's implementing regulations (40 CFR Part 1500 to 1508). The document, within established procedural standards, describes the potential effects on the human and antarctic environment of issuing a waste management permit to ASA and NSFA governing the use of materials, waste management practices, and environmental releases in support of the USAP. II. BACKGROUND A. The U.S. Antarctic Program It is the policy of the U.S. Government to maintain a presence in Antarctica, protect the antarctic environment, and continue to perform scientific research which can only be conducted under the unique conditions which exist there. The United States first established year-round scientific research stations in Antarctica in 1957-1958. At that time, NSF was responsible for the research component of the USAP. Later, a Presidential Directive assigned NSF overall management responsibility for the USAP. The NSF now manages the research program and provides logistics and operations support through a civilian contractor and other government elements such as the Naval Support Force, Antarctica and the U.S. Coast Guard. The USAP currently operates three permanent year-round stations in Antarctica: McMurdo Station on Ross Island, the Amundsen-Scott South Pole Station on the Polar Plateau, and Palmer Station on the Antarctic Peninsula. McMurdo Station is the principal support station for the USAP. The population of McMurdo Station generally ranges from 230-250 people during the austral winter (late February to early October) to 1,100-1,300 people during the austral summer (early October to late February). The South Pole Station population ranges from approximately 25-28 persons during the austral winter to 100-130 during the austral summer. At Palmer Station, the population ranges from 12 persons in the austral winter to 45 persons in the austral summer. USAP also charters two research vessels which provide research platforms for scientists working primarily in the Antarctic Peninsula region, the Drake Passage, and the Ross, Scotia, and Weddell seas. A Coast Guard icebreaker and Military Sealift Command ships assist with logistics support. USAP also maintains remote support camps at Marble Point and Byrd Surface Camp, and supports remote field parties in a variety of Antarctic locations. B. Development of Regulations The number of antarctic researchers and support personnel and tourists visiting Antarctica has steadily increased over the years, resulting in an increased potential for impacts on the antarctic environment. Antarctic Treaty nations recognized the potential effects of these impacts and adopted several Treaty recommendations addressing environmental issues. The United States Congress also recognized the importance of protecting antarctic flora and fauna, and in 1978, enacted the Antarctic Conservation Act (ACA). The ACA provides for the NSF to issue regulations designating pollutants and specifying required and prohibited actions, which address the prevention and control of the discharge or disposal of pollutants by United States citizens from any source within Antarctica. In 1990, NSF formed the Antarctic Pollution Control Task Group to assist NSF in formulating the pollution control regulations required by the ACA. The Group consisted of representatives from government agencies, private industry and environmental groups. During the same period, parties to the Antarctic Treaty began meeting to discuss, and eventually adopt, a Protocol on Environmental Protection to the Antarctic Treaty (the "Protocol"). Annex III of the Protocol mandates certain waste disposal and waste management practices in Antarctica. On June 29, 1993, the National Science Foundation (NSF), issued a final rule in the Federal Register (45 CFR Parts 670, 671 and 672) that amended its regulations to add provisions governing waste management and waste disposal in Antarctica. These changes implement the provisions of the ACA that require the Director of NSF to promulgate regulations designating and governing the release of pollutants in Antarctica. These regulations also state in 45 CFR 671.4, Prohibited acts: ...,it is unlawful for any U.S. citizen to (a) Use or release any banned substance in Antarctica; (b) Use or release any designated pollutant in Antarctica, except pursuant to a permit issued by NSF under subpart C of this part; (c) Release any waste in Antarctica, except pursuant to a permit issued by NSF under subpart C of this part; or (d) Violate any term or condition of a permit issued by NSF under subpart C of this part or any term or condition of any of the regulations issued under this part. The master permit application for materials and waste management and disposal was submitted in response to this final rule. C. Environmental Assessments In October, 1991, NSF published a Supplemental Environmental Impact Statement (SEIS) for the USAP. The SEIS describes the environmental impacts associated with USAP materials and waste management practices and construction activities. The NSF has conducted more specific evaluations of a variety of practices. A comprehensive list of these documents as well as the documents themselves are available at the NSF, Office of Polar Programs in Arlington, Virginia or through the Science and Technology Information System (STIS). STIS may be accessed through electronic mail via Internet, anonymous File Transfer Protocol (FTP), and other methods. For assistance in accessing or using STIS, telephone (703)306-0214 [TDD:(703)306-0090]; send an Internet e-mail message to: stis-request@nsf.gov, or write to:STIS, Division of Information Systems, Room 455, National Science Foundation, 4201 Wilson Blvd., Arlington, VA 22203. D. The Antarctic Environment Antarctica covers approximately 14.3 million square kilometers, an area larger than the United States and Mexico combined. Antarctica is the coldest continent on Earth. The average annual temperature at the South Pole is -49oC. The Earth's lowest known surface temperature, -89.2oC, was recorded in the Antarctic interior. Temperatures along the coastal areas occasionally exceed the freezing point (0oC) during the austral summer. The ice free ocean water temperatures are typically -1.8oC. Precipitation occurs often over much of the continent, usually as light snow. About 98 percent of the continent lies under a thick continental ice sheet which can reach thicknesses of more than 4,500 meters. Most of the ice surface is 2,000 to 4,000 meters above sea level. Numerous mountain ranges exist in Antarctica including the Transantarctic Mountains, the Prince Charles Mountains, and the Ellsworth Mountains. The Vinson Massif in the Ellsworth Mountains is 4,897 meters above sea level. The sea surface around Antarctica freezes and thaws annually, creating up to 20 million square kilometers of additional ice covered area during the austral winter. Antarctic fauna and flora have adapted to the distinctive annual cycle of continuous summer daylight and winter darkness by adjusting breeding cycles into a few summer months. Most of the Antarctic biomass is endemic, but significant numbers of birds and whales migrate in and out of the region. The SEIS describes land use, climate, weather and air quality, water and ecological resources at McMurdo Station, South Pole, and Palmer, Marble Point, and Byrd surface camp, as well as the remote field camps. The majority of land-based Antarctic activities undertaken by participants in the USAP occur in these locations. Background air quality data has been established for McMurdo Station. During the 1992-1993 austral summer season, an ambient air monitoring program was implemented and a monitoring network consisting of three monitoring stations located in and around McMurdo was installed. Each monitoring station included a variety of air sampling and monitoring instruments. The air pollutants that were measured included: total suspended particulate matter, particulate matter less than 10 microns in diameter (PM-10), sulfur dioxide (SO2), carbon monoxide (CO), nitrogen oxides (NOx), nitrogen dioxide (NO2), and polychlorinated dibenzo-p-dioxins and -furans. The analytical results indicate that air quality, even in "downtown" McMurdo, is very good relative to the U.S. National Ambient Air Quality Standards. These baseline data will be useful in assessing future environmental quality at McMurdo Station. During November, 1992, three sets of ambient water quality samples were collected from six locations at McMurdo Station including two control sites. The samples were analyzed for volatile organic compounds, semi-volatile organic compounds, trace elements and wastewater parameters. Low levels of several organic compounds, below ambient water quality criteria, were detected. Several metals appear relatively elevated in some wastewater samples compared to seawater controls but there is no evidence of elevated metal concentrations around the wastewater outfall. III. ALTERNATIVES ALTERNATIVE 1. "No-action" Alternative. This alternative is to take no action on the permit application, i.e., allow current waste management practices to continue without a formally binding permit document. It is presented to display the environmental effects of taking no action. Consideration of the "no-action" alternative is required in the evaluation of implementing the proposed action or alternatives. ALTERNATIVE 2. Approve the Permit Application with Conditions. Based on the information submitted in accordance with 45 CFR 671.6(a), approve the proposed material and waste management procedures and add conditions to clarify several issues. The permit application includes details on the use or release of nonhazardous materials as well as the use or release of substances containing chemicals, defined as designated pollutants under 45 CFR 671.3*. The permit application also includes a description of the types, expected concentrations and volumes of wastes and designated pollutants to be released in Antarctica and the nature and timing of such releases. * Designated pollutants include substances listed by source, generic or chemical name issued within or in regulations promulgated under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (42 U.S.C.A. 9601 et seq.); The Solid Waste Disposal Act as Amended by the Resource Conservation and Recovery Act (RCRA) (42 U.S.C.A 6901 to 6992k); and the Clean Air Act (CAA) (42 U.S.C.A. 7401 to 7671q). Actions and the status of USAP compliance and planning during the term of the permit under the two alternatives are summarized in Table 1. Table 1. Summary of Alternatives. Alternative 1 Alternative 2 Accidental releases No additional fuel or Ongoing planned containment the antarctic waste containment measures identified and environment measures mandated. intention for continued implementation stated. Assists in meeting Protocol goals.(1) Planned releases No requirement to Several technologies to the antarctic further reduce emissions identified for study to environment to air and discharges reduce air emissions and to water. wastewater discharges. Assists in meeting Protocol goals (2). Waste minimization, No requirements for more Several new programs for recycling and than current program. waste reduction and removal recycling identified. Assists in meeting Protocol goals (2). Compliance with USAP would not meet all In compliance with laws, regulations provisions of waste regulations; progress and international regulations for Antarctica towards meeting long- agreements term environmental objectives Planning for the No binding requirement for Plans to implement environment and long-term environmental environmental protection enforcement planning. No permit to use measures and basis for as basis for enforcement. enforcement in permit (1). (1) The short time frame of this initial permit precludes requiring the completion of design documents or the implementation of large scale improvements, other than those already in progress, during the term of the permit. NSF intends to require specific program objectives which would have sufficiently long terms to account for planning and logistical scheduling requirements and limitations. (2) The decision pertaining to the implementation of specific programs and technologies will be made by NSF and addressed in separate environmental documents. IV. ENVIRONMENTAL EFFECTS AND MITIGATING MEASURES The potential environmental effects associated with the two alternatives considered involve the accidental and planned release of pollutants; waste minimization, recycling, and removal; compliance with laws, regulations, and international agreements; and environmental planning and enforcement. The effects and level of mitigation under the alternatives are discussed below. A. Accidental releases to the antarctic environment Accidental releases to the antarctic environment have historically been the result of fuel spills during fuel transfer operations; leaks from fuel tanks and pipelines; small spills of liquids and solids during construction, maintenance and research activities; and severe storm events causing damage to facilities and the dispersal of windblown debris. Volatilization of spilled chemicals, fires, and equipment failures on combustion systems cause accidental releases of chemicals and particulates to air. Accidental releases of fuel and other pollutants cause contamination of soils, sediments, and water and may adversely affect the ecosystems in these media, depending upon the magnitude of the release and the specific pollutants involved. Windblown debris, aside from aesthetic concerns, poses a hazard to wildlife by potentially causing entrapment or being mistaken for food. During severe storm events, windblown debris also poses a safety hazard to personnel and may damage buildings and equipment. The impacts of accidental releases and their frequency of occurrence can be reduced through improvements to facilities such as adding secondary containment to fuel tanks and pipes and improvements to operations such as implementing new inspection and maintenance programs. Due to the short time frame in the proposed permit period, it is unlikely that the historic frequency and impacts of accidental releases will change under either of the two alternatives during the initial permit term. Alternative 2 would achieve reductions in future releases as a result of the completion of ongoing improvement projects referenced in the permit application documents. B. Planned releases to the antarctic environment Planned releases to the antarctic environment include sanitary wastewater discharges; air emissions from burning fuel for transportation, power, and heating; and dust from construction activities. Environmental effects from planned releases which have been noted in the past include slightly elevated concentrations of particulates in the air in the area of McMurdo Station and solids buildup near the sanitary wastewater outfall. As noted in the discussion of accidental releases, due to the short term of the initial permit period, no change in the environmental effects from planned releases during the term of the permit would likely occur under either of the two alternatives. Alternative 2 would achieve reductions in future planned releases. C. Waste minimization, recycling, and removal Waste minimization, recycling, and removal are necessary to protect the antarctic environment. Reducing waste, reduces waste handling requirements which reduces labor, equipment and fuel needs. These reduce baseline infrastructure requirements which benefit the environment through reductions in planned releases. Recycling used oils through fuel blending and using reclaimed glycols, both programs under study, reduces storage and transport requirements for these materials. Accidental releases are also reduced in that the amount of material stored and handled decreases, thus lessening the possibility for an accident to occur moving drums and other containers. Removal of wastes from Antarctica protects the region from releases to soil, water, ice, and air associated with on-site disposal options. While alternatives 1 and 2 both include waste minimization, recycling and removal programs, alternative 2 would provide for the formal incorporation of these programs into a permit document which would directly guide NSF's planning and budgeting processes. D. Compliance with laws, regulations, and international agreements The Purpose and Need and Background sections of this document discuss NSF's waste regulations and permitting requirements. Alternative 2 achieves compliance with pertinent regulations. The environmental benefits of Alternative 2 were outlined in the discussion of planned and accidental releases and waste minimization, recycling, and removal. Alternative 1 would eventually result in the discontinuation of the USAP, since no releases of waste or designated pollutants (including air emissions from heating units and power plants), or use of designated pollutants would be allowed. E. Environmental planning and enforcement Environmental planning benefits a region through identifying integrated management strategies. Plans developed based on understanding pollutant source and transport mechanisms enable solutions to be implemented to achieve the greatest benefits in reduction of pollutant releases to the air, soil, ice, and water and achieve a cleaner environment in the most cost effective manner. Enforcement actions enable the NSF to minimize environmental impacts, if elements of environmental plans incorporated into permit documents are not implemented. Alternative 2 promotes environmental planning efforts which will reduce pollutant releases when implemented. F. Short-term effects There will be no short-term effects on the environment under either of the two alternatives during the period of the proposed initial permit term. Any proposed changes to equipment, facilities, or operations which would result in substantial reductions in releases of pollutants to the antarctic environment would not be implemented within the proposed initial permit term, with the exception of ongoing improvements discussed in the permit application documents and commenced in the 1993/1994 austral summer. New initiatives identified in Alternative 2 would only be in the planning, procurement, or construction phases at the end of this time frame. G. Long-term and cumulative effects Alternative 2 would likely result in the reduction of pollutant releases in the future. Improved fuel management and containment and new waste reduction and recycling programs are among the measures to be implemented or considered for study and implementation under Alternative 2 which will reduce pollutant releases to soil, water, air, and ice; minimize the quantifiable environmental impacts of the human presence in Antarctica; and facilitate the recovery of areas polluted by past practices. Alternative 1, a continuation of current operations, would eventually result in the dismantling and retrograding of all USAP facilities and the cessation of the USAP, since activities necessary for maintaining a human presence in Antarctica would be precluded without a waste permit. H. Unavoidable effects and irretrievable and irreversible commitment of resources Alternative 2 will result in the continuation of waste management operations in Antarctica. The waste management infrastructure requires labor, equipment, and fuel. Use of fuel for transportation of materials and personnel, operation of equipment, and heating workplaces and living structures is an irretrievable use of natural resources. Waste reduction and recycling strategies associated with Alternative 2 should reduce the size and related fuel demands of the materials and waste management program. Alternative 1 would result in the continued consumption of fuel at current levels until the cessation and dismantling of the USAP. I. Consistency with the plans and programs of the NSF and others Alternative 2 supports international agreements and United States laws and regulations pertaining to waste management in Antarctica. It would minimize the impact of work in support of the USAP on the antarctic environment, which is consistent with the plans and desires of the NSF, U.S. scientific researchers, and representatives and researchers from other nations working in Antarctica. Alternative 1 would not meet all the requirements of existing regulations. 6.0 CONSULTATION WITH OTHERS NATIONAL SCIENCE FOUNDATION, OFFICE OF POLAR PROGRAMS Mr. Arthur Brown Head SEH Implementation Team /abrown@nsf.gov/(703)306-1032 Dr. Shih-Cheng Chang Environmental Engineer/schang@nsf.gov/ (703)306-1032 Mr. Robert Cunningham NEPA Compliance Manager/rcunning@nsf.gov /(703)306-1031 Dr. Jane Dionne Acting Environmental Officer /jdionne@nsf.gov/(703)306-1033 Mr. Thomas Forhan Head, Antarctic Staff/tforhan@nsf.gov/ (703)306-1031 Mr. Peter Karasik Associate Compliance Manager /pkarasik@nsf.gov/(703)306-1031 NATIONAL SCIENCE FOUNDATION, OFFICE OF GENERAL COUNSEL Ms. Anita Eisenstadt Assistant General Counsel/ aeisenst@nsf.gov/(703)306-1060 Ms. Miriam Leder Assistant General Counsel/ mleder@nsf.gov/(703)306-1060 ANTARCTIC SUPPORT ASSOCIATES, INC. Ms. Carol Andrews Environmental Engineer/ ANDREWCA.ASA@asa.org (Internet)/ 1-(800)688-8606 JD:PRK:pk/permea4.doc