Title  : Fuel Tanks & Berms-McMurdo
Type   : Antarctic EAM
NSF Org: OD / OPP
Date   : December 31, 1992
File   : opp93097


                                       DIVISION OF POLAR PROGRAMS
                                        OFFICE OF THE ENVIRONMENT
                                                     202/357-7766

MEMORANDUM

   Date:  December 31, 1992

   From:  Environmental Officer, DPP

Subject:  Environmental Action Memorandum (Installation of Waste
            Fuel Holding Tanks and Berms, McMurdo Station)

     To:  Safety and Health Officer, DPP
          Facilities Engineering Projects Manager, DPP
          Environmental Engineer, DPP
          Environmentalist, ASA
          Commander, NSFA

   REFs:  Environmental Action Memorandum (Collection of Earth
            Fill Materials at McMurdo Station During the
            1992-1993 Season), Dated December 1, 1992

          Environmental Action Memorandum (McMurdo Station Sewer
            Outfall Quay Reinforcement Project),
            Dated December 30, 1992.


This Environmental Action Memorandum describes the need for, and
location of, proposed actions to install holding tanks for waste
fuel collected at McMurdo Station and awaiting retrograde from
Antarctica on the annual fuel supply vessel.  The Environmental
Officer posed a set of questions relating to the proposed
actions, and to the potentially affected environment.  These
questions were responded to by Antarctic Support Associates,
Inc.'s (ASA) Environmental Engineer, C. Andrews; and Mechanical
Engineer, S. Bredl on December 31, 1992; background information
as well as the questions and responses are shown below:

Background

As part of maintaining McMurdo Station's fuel storage and
transfer system, and general station operations, waste fuel is
generated.  McMurdo's waste fuel, colloquially termed "slop",
consists of fuels contaminated with such substances as water,
dirt, oil, or antifreeze.  Most waste fuel comes from one of two
sources:  1) fuel pumped from the bottom of fuel storage tanks
that have been found to contain too much sediment; and 2) fuel
recovered from spills.  In the past waste fuels have been stored
in two tanks located on Hut Point.  The fuel is transferred
annually from the waste fuel tanks to the oil tanker for retro-
grade from Antarctica and refinement, and reuse elsewhere.

The existing waste fuel tanks near the pier leak and are not in
useable condition.  Two 57,000 liter (15,000-gallon) tanks
previously located at New Zealand's Scott Base have been placed
temporarily as shown on Attachment 1.  These tanks would be used
as the proposed new waste fuel tanks.  The Contractor proposes to
construct a secondary-containment area lined with 100-mil, high-
density polyethylene (HDPE).  The replacement tanks would then be
installed within the containment area.


GENERAL

 1.  What is the specific purpose of the proposed activity?

     The purpose of the activity is to replace McMurdo Station's
     existing waste fuel holding tanks.

        What alternatives to the proposed activity have the
        Program and the Contractor considered?

        The Contractor has considered four main alternatives:
        1. using different tanks;
        2. identifying different locations for the new tanks;
        3. repairing the existing tanks; and
        4. the "no-action" alternative.

        Have probable impacts of all alternatives been
        considered by the Program and the Contractor?  Please
        explain how.

        The potential impacts of the proposed activity include
        changing surface water flow patterns; generation of
        fugitive dust emissions during installation; and,
        improvement to the integrity of the waste fuel storage
        system at McMurdo Station.  Purchasing and installing
        different tanks (e.g., double-walled tanks) would cause
        significant delay in replacing the existing tanks that,
        currently, have no secondary containment; and, this
        would increase the costs of the project, overall.  The
        proposed location was selected so as to minimize the
        aesthetic and potential environmental impacts (e.g.,
        possibility for accidental spills during transfer of
        waste fuels into and out of the waste fuel holding
        tanks).  This would be accomplished while meeting the
        operational requirements of the station's fuel system.
        For repair, if they are repairable, the existing tanks
        would have to be emptied with other holding tanks being
        used during the repair.  This would be similar to the
        proposed and preferred activity.

        Should the chosen alternative involve potential impacts,
        how would these impacts be mitigated by the Program or
        the Contractor?

        The flow of water around emplaced secondary-containment
        berms for the new waste fuel holding tanks would be
        designed to avoid promotion of water ponding.  Any
        ditches around the containment berms that would prove
        steep enough to cause excessive erosion would be lined
        with "rip rap" or with a metal, open-channel culvert.
        Dust emissions would be minimized by spraying water
        during installation, when feasible.  Aesthetic impacts
        would be considered when selecting the exact location of
        the containment berms relative to the adjoining hillside
        and road.

        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 replacement tanks are previously used tanks
        with substantial remaining, useful life.  This avoids
        the costs of purchasing and shipping new replacement
        tanks long distances to McMurdo Station.  The former
        waste fuel tanks can not be reused unless they are
        rehabilitated so as to meet such Fuel Tank Container
        Codes as NFPA 30 and API 650.  The lined, bermed area
        would require more maintenance (i.e, snow removal, and
        liner inspection) than the existing, unlined, tanks.
        The secondary containment would greatly reduce, however,
        the chances for contamination of the surrounding area
        and associated clean-up costs.


LAND USE AND PLANNING

 2.  Where would the proposed activity be located, specifically?

     The replacement tanks would be placed at the base of the
     hill beneath Bulk Fuel Tank "D-1" on the northeast side of
     the main road to Hut Point.  See attached map.

        Have alternative locations been considered by the
        Program or the Contractor?  If yes, which are they; if
        no, explain why.

        Yes.  The Contractor considered placing the new waste
        fuel holding tanks in the area between Bulk Fuel Tanks
        "D-1" and "D-2".  This location was rejected according
        to an American Petroleum Institute code.  Under that
        code and at that site the minimum distance required
        between tanks would not be achievable.

        Placing the replacement tanks near the site of the
        existing waste fuel tanks near the station's ice wharf
        was rejected as:  1) the new site would reduce driving
        distance to tanks; 2) the new site is farther from the
        water, reducing the potential for a waterborne spill;
        and, 3) tanks at the proposed site may still be emptied
        directly into the oil tanker using flexible hose (i.e.,
        the "dry-break" type of hose used to transfer fuel to
        Williams Field) or using the station's tanker truck.

        Also, creating a site for the replacement waste fuel
        tanks on the other side of the road, nearer Building
        183, was considered.  This location was rejected due to
        the quantity of local earth fill required to create a
        level area, and due to safety concerns associated with
        the steep embankment along the other side of the road.

 3.  How would any aesthetic impacts to the area from the
     proposed activity be handled by the Program or the
     Contractor?

     The new tanks would be placed within a lined, bermed
     containment area.  The Contractor would emplace the berms
     to fit the natural aspect of the area as well as its
     current topography.

     Removal of the existing, rusted waste fuel tanks (that are
     surrounded by fuel-soiled earth and with debris associated
     with their supports) would improve the aesthetics of the
     area along the road to Scott's Hut.  This road is often
     used for recreational walking.  Also, the existing waste
     fuel tank site is highly visible from ships.

 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.

     Yes.  Approximately 50 cubic meters of local earth fill
     material would be required to construct both a level area
     and the containment berms.  Actions associated with collec-
     tion of earth fill during the 1992-1993 season have been
     considered in a previous Environmental Action Memorandum.

 5.  Would the proposed activity change the traditional use(s)
     of the proposed (or chosen) site?  If yes, how; if no, why.

     Currently, the site is a small, vacant area between a road,
     a steep hillside, and fuel lines on stanchions.  The area
     is near existing fuel storage and transfer structures.  The
     area clearly has been regraded one or more times in the
     past as part of installing the pad for Bulk Fuel Tank "D-1"
     and creating the roadway.

 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 proposed site is relatively near to the points of
     generation of waste fuel, yet, it is not in a highly
     populated area.  The existing hillside, utility pole and
     fuel lines would be worked around as necessary to fit the
     tanks and berms into the proposed space.  The site is
     environmentally suitable and preferable over a site that
     has not been disturbed previously.


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])?

     Placing the tanks near a road may entail safety concerns.
     The containment berm, however, would help to protect the
     tanks from a vehicle or falling cargo accident.  The pro-
     posed activity would reduce the amount of fuel loss to the
     environment by allowing the existing, leaky waste fuel
     tanks to be retired and they would provide secondary
     containment for the replacement tanks.

 8.  Would the proposed activity change ambient air quality at
     the proposed (or chosen) site?  If yes, how; if no, why.

     No.  Dust emissions during berm construction would be
     suppressed using sprayed water, when feasible.  The
     structures resulting from the proposed activity, two tanks
     sitting within a bermed area, would be passive and would
     not produce air emissions.  During transfer of waste fuel
     into and out of the tanks some volatile petroleum compounds
     would escape.  However, this would not differ from the type
     or quantity of emissions resulting from use of the current
     waste fuel tanks.

 9.  Would the proposed activity change water quality or flow
     (drainage), at the proposed (or chosen) site?  If yes, how;
     if no, why.

     Yes.  Ditches would be constructed to divert surface water
     around the secondary containment berms.  The ditches would
     direct water back into the existing drainage system.

10.  Would the proposed activity change waste generation or
     management at the proposed (or chosen) site?  If yes, how;
     if no, why.

     No.  The tanks would hold waste fuel and not affect the
     quantity of waste fuel generated.  As all tanks involved in
     the project would be cleaned and reused (in actions to
     reinforce McMurdo's wastewater outfall quay) the old tanks
     would not become waste.  Efforts made by the Contractor and
     the Naval Support Force Antarctica to reduce fuel spills
     would help reduce the amount of waste fuel generated.

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.

     No.  The tanks and berms would not require energy once they
     are in place.  Energy and vehicles would be required to
     construct the berms and place the tanks.

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.  The proposed activity would not occur near any sites
     of scientific research, nor would it produce adverse air or
     water emissions, electromagnetic interference, or noise.

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.  No such ecosystems exist in the vicinity of the
     proposed activity.

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.  The site is near a small area where surface water
     tends to pond.  The color of the ponded water has turned
     green, indicating the presence of algae.  However, the
     proposed construction would not affect the pond.  The
     ponded water appears on occasion to be contaminated with
     petroleum products as a result of past fuel spills,
     indicating it has already been affected by human activity.
HUMAN VALUES

15.  Would the proposed activity encroach upon any historical
     property of the site?  If yes, how; if no, why.

     No.  The vacant area is not considered historical 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).

     The tanks could be removed easily from the site in the
     future.  The liner could be removed from the berms and the
     fill material could be regraded as necessary as part of
     decommissioning.


                             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 fuels and waste management at the station.  With adherence to
U.S. Antarctic Program policy on earth fill materials collection
the proposed activity will improve the environment within and
near McMurdo Station.  The Program and the Contractor are
authorized to undertake the proposed actions.





                                 Sidney Draggan


Attachments