Title  : Hallett Station Cleanup
Type   : Antarctic EAM
NSF Org: OD / OPP
Date   : November 1, 1993
File   : opp94009

National Science Foundation
                    Office of Polar Programs

                   ENVIRONMENTAL DOCUMENT AND
                FINDING OF NO SIGNIFICANT AND NOT
             GREATER THAN MINOR OR TRANSITORY IMPACT

               Hallett Station Cleanup - Phase I
                       Site Stabilization

                        NOVEMBER 1, 1993

I.  Findings

The National Science Foundation (NSF) has prepared an Initial
Environmental Evaluation (IEE) and an Environmental Assessment
(EA) as a combined environmental document, for waste
stabilization of Hallett Station, Antarctica.  Based on the
analyses in the environmental document (IEE/EA), NSF Office of
Polar Programs (OPP) has determined the proposed action,
implementation of Alternative A is not a major federal action,
within the meaning of the National Environmental Policy Act
(NEPA) of 1969 nor is the action one which would have a greater
than minor or transitory effect on the Antarctic environment
within the meaning of the NSF implementing requirements for the
Protocol on Environmental Protection in the Antarctic Treaty (45
CFR 641).  Therefore, an environmental impact statement and a
comprehensive environmental evaluation will not be prepared.

The selected alternative, A, provides for the stabilization of
wastes at the Hallett Station and is reasonable and consistent
with NSF's efforts to improve the Antarctic environment.

[signed]_______________________         [November 1, 1993]__
Mr. Erick Chiang                             Date
Manager
Polar Operations Section
Office of Polar Programs

II.  PURPOSE AND NEED FOR THE PROPOSED ACTION

The NSF Office of Polar Programs (OPP) proposes to stabilize
fuel, solvents, other hydrocarbons, and antifreeze wastes stored
at Hallett Station, Antarctica.  Phase I, the proposed action,
would stabilize wastes which could leak from storage containers.
Phase II, an action to be evaluated at a later date, would
dismantle storage tanks and remove wastes for retrograde to
McMurdo Station.  The phasing of the cleanup and reclamation of
Hallett Station is intended to reduce potential negative impacts
on the local penguin population and minimize environmental
effects on the Antarctic environment.

Hallett Station was established in March 1957 as one of the
original International Geophysical Year (IGY) stations.  The
station is located on the Antarctic coast at 72 deg 19'S, 170 deg
13'E (See Attachment 1).  The station, operated jointly by the
United States and New Zealand until a March 6, 1964 fire
destroyed the main scientific building, was occupied by U.S.
scientists who conducted biological research during the austral
summer months from 1965 to 1973.  The station provided
communications and weather reporting for the air route between
Christchurch, New Zealand and McMurdo Station, Antarctica.  In
addition, it served as an alternate landing field when Williams
Field in McMurdo Sound was closed.

Since the station's closure in 1973, the United States and New
Zealand have attempted to reclaim the approximately 22.2 hectare-
site to the original pristine environment.  Buildings, equipment,
and rubbish have been successfully removed.  In 1988, a joint
U.S. Navy and civilian contractor team removed approximately
189,250 liters of off-specification diesel fuel-marine (DFM) from
a 378,500-liter fuel tank.  Still remaining, however, is a fuel
cache of:

     1)  Approximately, 53,000 liters of off-specification DFM,
     salt water, and sludge contained in a large fuel tank;

     2) Four aircraft tanks (2.13m x 1.83m x 0.81m), three with
     lubricating oil and one with antifreeze;

     3) Two 3028-liter tanks containing lubricating oil;

     4) One cylinder tank (2.29m x 1.22m x 0.76m) of antifreeze;
     and

     5) Twenty-nine, 208-liter drums consisting of; one DFM, four
     gear oil, two kerosene, one solvent, five mogas, seven oil,
     and nine white gas drums.

Several proposals by the Naval Support Force, Antarctica (NSFA)
and Antarctic Support Associates (ASA) have been made to remove
the fuel cache.  The most recent was developed during the 1990-91
season (See Attachment 2).  However, this cleanup plan was not
implemented.  On December 4, 1991, a site visit by Dr. Gary
Miller, Ornithologist, University of New Mexico, and Mr. Craig
Martin, ASA Director of Engineering, revealed that the drums
(item 5, above) and the smaller tanks (items 2, 3, and 4, above)
although not leaking, had significant deterioration.  The failure
of aging fuel containers (items 2 to 5, above) could leak wastes,
contaminate snow and soil, and/or negatively impact the penguin
population.

II.  ALTERNATIVES

To stabilize the most potentially damaging wastes from the fuel
cache, several alternatives were considered.  In one alternative,
it was suggested that the wastes should be burned on-site to
eliminate any potential damage from leaking containers or spills.
Waste Regulations (45 CFR 671.12) for the U.S. Antarctic Program
(USAP) require that fuel (both liquid and solid); and fuel, oil
and chemical drums that constitute waste must be removed from
Antarctica.  Although, the latter may remain in place if removal
would prove to be damaging to the environment.  The suggested
alternative would fit the definition of "open burning" in the
regulation which is very specific:

     "Open burning of wastes is prohibited at all permanent
     stations, and shall be phased out at all other locations by
     March 1, 1994.  If it is necessary to dispose of waste by
     open burning prior to March 1, 1994, allowance shall be made
     for the wind direction and speed and the type of waste to be
     burnt to limit particulate deposition and to avoid such
     deposition over areas of special biological, scientific,
     historic, aesthetic or wilderness significance."

Hallett Station is no longer a permanent facility.  The fuel,
solvents, and other hydrocarbons could be burned before March 1,
1994.  However, it would be difficult to make allowances for the
direction and speed of the wind to limit particulate deposition.
The fuel contains sediment and contaminants that could increase
air pollution and effect penguins nesting nearby.  The potential
for damage to the penguin population is unacceptable.  The
alternative was not further evaluated.

In another alternative, it was suggested that the wastes could be
brought back to McMurdo for retrograde to the United States this
season.  To minimize the possible effects on the local penguin
population, it was determined that the stabilized wastes should
remain on-site for one winter before removal and dismantling of
remaining storage tanks.

Two alternatives were considered:

     Alternative A  For on-site storage this winter, transfer
                    contents of smaller tanks containing wastes
                    into 101 new 208-liter drums and overpack
                    into 322-liter overpack drums and replace 29
                    old drums in overpacks.

     Alternative B  No Action (required for analysis of effects).
                    Leave the area as is with the expectation of
                    cleaning-up the site next summer.

IV.  ENVIRONMENTAL EFFECTS AND MITIGATING MEASURES

1.  Terrestrial and Aquatic Ecosystems

Either alternative has the potential of impacting the local
terrestrial habitat and resident penguin population.  An Adelie
penguin rookery with approximately 80,000 birds is nearby.  The
closest colony is approximately 16 meters from the site.  Work in
Alternative A can disturb penguin breeding and possibly injure
individual birds who may venture into the work area.  Although
spills could negatively impact the colony, the work would be
conducted in an area away from the largest concentration of
birds.  On-site personnel could quickly and efficiently clean up
any spills with minimal disturbance to birds.

Alternative B could have negative impacts on the penguin colony.
At present, some birds are nesting in and around some of the
drums.  Even the smallest leakage from a tank or drum could have
harmful effects, because a spill would not be immediately cleaned
up.  Alternative B could cause chronic effects on penguins due to
the emissions of volatile compounds should leaks develop.  In
addition, a tank or drum failure could complicate the next
season's site reclamation, cause environmental damage, and add to
overall clean-up costs.

Mitigation measures in Alternative A will minimize the
disturbance to the penguin colony and avoid toxic material entry
into aquatic ecosystems.  Attachment 3 is a report by Dr. Miller
who made several recommendations to minimize rookery disturbance
during the penguin breeding season.

The immediate work area will be fenced to keep out birds.
Workers would be required to regularly survey the surroundings to
ensure that penguins do not enter the work area.  Should penguins
penetrate the barrier, workers would herd them away taking care
not to handle the birds.

October 25 to November 18 is the most sensitive period for the
penguins.  They are building nests during, finding their mates,
and laying eggs.  Once the eggs are laid, penguins resist leaving
their nests.  Dr. Miller suggests that the digging out of snow
covered drums and overpacking of these drums should begin after
November 18.  These recommendations will be followed.

Alternative A would have no adverse effect on water quality.
Precautions would be taken to minimize fuel spills.  In the event
of a spill, chances of the spill reaching open water are minimal
because personnel would be on-site to mitigate any spills or
leaks from tanks or drums.  Alternative B could impact land and
water quality if tanks or drums fail due to corrosion.  Although
the site is approximately 460 meters from the shore, wastes could
reach the water.

2.  Land Uses

In Alternatives A or B, no construction would be required which
would alter the terrain or produce related waste and debris.  In
Alternative A personnel working at the site will live in tents,
removed when the project is completed.  All solid waste,
including kitchen garbage and human waste, will be managed on-
site to prevent litter and retrograded to McMurdo Station.

All solid and human waste will be retrograded to McMurdo for
processing and disposal.  Containers for storing solid waste will
be provided by ASA Waste Management.  Separate containers will be
provided for human waste.  Drums containing solvent and
antifreeze will be identified and properly labeled for transport
to McMurdo.

Spill control equipment (drip pans, oil adsorbents, spill kits
and drums) will be available to contain and clean up any spill.
Personnel working at the site, will receive spill response
training from the McMurdo spill response team.  A spill
contingency plan specific to the cleanup action will be prepared
for them to follow in the event of a spill.

3.   Science Projects

The site is approximately 600 meters from Specially Protected
Area (SPA) No. 7.  SPA's are areas of outstanding scientific
interest listed and in the Agreed Measures for the Conservation
of Antarctic Fauna and Flora and are accorded special protection
to preserve their unique ecology.  Hallett Station is important
for its rich avifauna and diverse vegetation.  No research by NSF
or others is currently ongoing or planned for the SPA.  All
cleanup activities will be conducted outside the SPA boundaries.
No impacts to the area will be expected from Alternative A.
Alternative B could affect potential science projects involving
the penguin colony or site ecology.

4.   Cumulative Impacts

Alternatives A has a positive cumulative effect, in that the risk
from leakage of waste fuel is significantly reduced as compared
to Alternative B.  Cumulative effects of Alternative A, as well
as B are not considered to be significant or long-term, because
the site is to be cleaned-up next season.

VI.  CONSULTATION WITH OTHERS

Ms. Carol Andrews        Environmental Engineer, Antarctic
                         Support Associates (ASA)
Mr. Dave Bresnahan       Systems Manager, Office of Polar
                         Progarms (OPP)
Mr. Erick Chiang         Manager, Polar Operations Section, OPP
Mr. Robert S. Cunningham Manager, NEPA Compliance, OPP
Dr. Jane Dionne          Acting Environmental Officer, OPP
Ms. Anita Eisenstadt     Office of General Counsel, NSF
Dr. Bernhard Lettau      Program Manager, Polar Oceans and
                         Climate, OPP
Dr. Polly A. Penhale     Program Manager, Polar Biology and
                         Medicine (PBOM), OPP
Mr. Terry Johnson        Environmental manager, ASA
Mr. Eric Juergens        Director, Saftey, Environment & Health,
                         ASA
Mr. Craig Martin         Director Engineering, ASA
Dr. Gary Miller          Principle Investigator, University of
                         New Mexico
Dr. Neil Swanberg        Associate Program Manager, Polar Biology
                         and Medicine (PBOM), OPP

ATTACHMENTS

1.   Map of Hallett Station

2.   Hallett Station Clean-Up Plan

3.   Miller, G., Potential Impacts of Final Cleanup of Fuel
     Containers at Cape Hallett for the 1992/1993 Austral Summer:
     Report on inspection visit 4 December 1991.